Comments for RIN 1205-AC21, Prohibiting Illegal Discrimination in Registered Apprenticeship Programs

Re: Comments for RIN 1205-AC21, Prohibiting Illegal Discrimination in Registered Apprenticeship Programs (submitted September 2, 2026, via regulations.gov)

I. Introduction

On behalf of the Institute for Women’s Policy Research (IWPR), I am writing to submit comments in response to the recent notice of proposed rulemaking, Prohibiting Illegal Discrimination in Registered Apprenticeship Programs, RIN 1205-AC21.

Since 2015, the US government has invested more than $1.6 billion¹ through the US Department of Labor (Department) to expand apprenticeships to new occupations and sectors, modernize the apprenticeship system, and improve the gender and racial diversity of apprentices. This included updating and expanding the 1971 nondiscrimination provisions through the 2016 Equal Employment Opportunity (EEO) in Apprenticeship Final Rule, that, among a number of provisions, established program utilization goals and targeted outreach, anti-harassment training, complaint and compliance processes, and data collection requirements to increase opportunities for highly skilled individuals, regardless of their sex, gender, gender identity, race, ethnicity, or disability.²

Thanks to the Department and its Office of Apprenticeship (OA) investment and commitment, the number of women apprentices has tripled over the last decade, with gains across all racial and ethnic groups, and the share of women among registered apprentices increased—though women remain a minority, at just 14.3 percent.³

The Department’s proposed rule, which largely rescinds the 2016 EEOC 29 Code of Federal Regulations (CFR) Part 30 nondiscrimination requirements and conforms Part 29 provisions, threatens the progress women have made—and the gains still to be made—in their representation in apprenticeships. IWPR strongly opposes the proposed rule and would encourage leaving the current 2016 Final Rule intact with increased resources to further support its implementation. The proposed rule, if finalized and enacted, would have negative consequences for all underrepresented populations in apprenticeships.