When Executive Order 14026 was rescinded in March 2025, many contractors asked: Does this mean EO 13658 is back in play? After all, wage determinations still include language limiting EO 13658 applicability to contracts not extended or renewed after January 30, 2022. So, what does this mean for EO 13658?
The Short Answer
No—EO 13658 does not apply to contracts extended or renewed after January 30, 2022. The rescinding of EO 14026 does not revive EO 13658 coverage terms for later contract actions unless a new order or regulation explicitly says so.
Why the Confusion?
EO 13658 originally set a minimum wage for federal contractors, but its applicability ended for contracts renewed or extended after January 30, 2022, when EO 14026 superseded it and established a higher wage requirement—until EO 14026 was rescinded. Contrary to popular belief, that rescission did not reinstate the applicability of EO 13658 for later actions.
What This Means for Your Contracts
- Contracts extended on or after January 30, 2022 are not covered by EO 13658.
- A contract awarded or extended (i.e., on which an option is exercised) on January 1, 2026, for example, would not be subject to EO 13658 or the minimum wage established by.
- Contractors performing on contracts awarded or extended after that date are only required to abide by the applicable Wage Determination.
- Although Wage Determination language may still reference EO 13658, there above stated parameters for applicability apply for any enforcement actions.
Compliance Tips for Contractors
- Review Your Wage Determinations Carefully
If EO 13658 language appears, confirm whether your contract action date falls before January 30, 2022. Do not assume coverage based on outdated language.
- Follow Current Minimum Wage Laws
Unless your contract specifically incorporates an executive order requirement, apply the Wage Determination rates corresponding to the labor classification applicable to the duties performed by your workers or the federal or state minimum wage standards, if they are higher.
- Document Your Compliance Steps
Keep written records of your interpretation and any communication with contracting officers. This protects you if questions arise later.
- Stay Alert for New Guidance
Future executive orders or DOL regulations could change the landscape again. Subscribe to official updates and industry alerts.
The Bottom Line is EO 13658 remains dormant for contracts extended or renewed after January 30, 2022. Compliance now hinges on standard wage laws, such as the Davis Bacon Act, Service Contract Act, Fair Labor Standards Act, or applicable State Wage Laws—not outdated executive orders.
Ready to simplify compliance?
For expert guidance on contract updates and workforce strategies, contact us today! Explore Onsi Group’s fringe benefits, auditing, & consulting services or attend a Prevailing Wage Compliance Training through Onsi University.
Author: Emmi Gaytan
Editor: Aaron Ramos
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