PolicyBrief
S. 920
119th CongressMar 10th 2025
Preventing Child Labor Exploitation in Federal Contracting Act
IN COMMITTEE

This Act mandates increased accountability for federal contractors regarding child labor violations, significantly raises associated civil penalties, and requires new training and studies on compliance.

Joshua "Josh" Hawley
R

Joshua "Josh" Hawley

Senator

MO

LEGISLATION

Federal Contractors Must Certify No Child Labor Violations; Fines Jump to $100K and $500K

The “Preventing Child Labor Exploitation in Federal Contracting Act” is pretty straightforward: it aims to stop companies that break child labor laws from getting federal contracts, and it makes those violations much more expensive. If you’re paying taxes, this bill is about making sure your money isn't funding exploitation.

The New Vetting Process: Who Gets the Contract?

Within 18 months, federal contracting rules are getting a major overhaul. Any company bidding on a federal contract will have to certify every year whether they’ve had a final ruling, arbitration decision, or civil judgment against them for violating child labor rules (Section 12 of the Fair Labor Standards Act) in the last three years (SEC. 3). Think of it like a mandatory background check for labor compliance, and it doesn't stop with the prime contractor. If a large construction firm wins a federal job, they also have to get the same certification from every subcontractor and service provider they plan to use. This means the compliance net is cast wide, covering everyone down the supply chain.

Accountability or the Blacklist

If a company admits to a violation, they aren't immediately blacklisted, but they have to agree to corrective actions negotiated with the Secretary of Labor. This is where the rubber meets the road. If they admit the violation but then fail to follow through on those agreed-upon fixes, they get placed on a new ineligibility list. Once on that list, executive agencies can’t award them contracts for at least four years. This establishes a clear path: fix your past mistakes or lose access to lucrative federal work. For companies that try to cheat the system and knowingly lie on their certification forms, the penalty is even steeper, triggering suspension and debarment proceedings and potentially facing False Claims Act penalties (SEC. 3).

Making the Fines Hurt

Beyond contract eligibility, this bill drastically increases the financial penalties for violating child labor laws. For one type of violation, the maximum fine jumps from $11,000 to a staggering $100,000. For more serious or willful violations, the maximum fine goes from $50,000 to $500,000 (SEC. 4). This isn't just a slap on the wrist anymore; these new amounts are designed to act as a serious deterrent, especially for larger corporations where a few thousand dollars might just be the cost of doing business. These higher fines kick in immediately upon the bill becoming law.

Training the Watchdogs and Taking Inventory

The bill also mandates that the Secretary of Labor create new training programs to teach staff—including personnel at the Department of Health and Human Services and Homeland Security—how to spot and stop child labor violations (SEC. 5). This makes sense: if you’re going to enforce new rules, you need to make sure the people on the ground know what they’re looking for. Furthermore, the Government Accountability Office (GAO) is required to conduct a study within two years to figure out exactly how widespread child labor violations are among federal contractors (SEC. 6). This will give Congress and the public hard data on the scope of the problem.

The Fine Print: No New Budget

One detail worth noting for taxpayers is that the bill explicitly states it authorizes no additional funds (SEC. 7). This means the Department of Labor and other agencies will have to implement this entire new system—the certifications, the corrective action negotiations, the ineligibility list management, and the training programs—using their existing budgets. While the goal is laudable, the administrative lift required to manage this new compliance regime across the entire federal contracting landscape could be substantial, potentially straining existing resources.