EEOC Quorum Restored: Five Critical Enforcement Shifts for Employers

Commissioner Brittany Panuccio’s confirmation on October 7, 2025 restored the EEOC’s quorum, removing the constraints that limited Chair Andrea Lucas during the eight-month period when the Commission operated with just two members. The Commission can now formally adopt new guidance, rescind prior guidance and policies, authorize litigation, approve amicus briefs, and modify its Strategic Enforcement Plan —actions that were not possible without three commissioners.

Based on Chair Lucas’ stated priorities and enforcement actions already underway, employers face 5 critical enforcement shifts.