DEI Forecast: Cloudy, With a 100 Percent Chance of Backpedaling

Christopher McCormick, Founder & CEO, Visionary Consulting

Marisol had written the original language herself, four years earlier. "We believe a diverse workforce makes us stronger." It sat on the careers page, in the investor deck, in the values poster in the lobby that nobody read but everybody walked past.

Now legal counsel was in her office with a different recommendation. Quietly retire the word. Keep the underlying practices if she wanted — nobody was telling her to stop hiring the way she'd been hiring — but the word itself had become a "liability" in a way it hadn't been when she wrote it. Marisol asked the obvious question: if the practice stays and only the word goes, what exactly are we protecting?

Legal didn't have an answer to that one. That wasn't their job.

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The compliance question is hiding a values question

Between 2025 and 2026, federal policy moved decisively away from encouraging race-conscious equity programs and toward a standard of strict formal neutrality.

Executive orders early in that period required organizations receiving federal grants and contracts to certify their compliance with antidiscrimination law, and directed agencies to eliminate disparate-impact analysis — the legal framework that allowed a policy to be challenged for its effects rather than only its stated intent — wherever possible. The Department of Justice and the Department of Education followed by stripping disparate-impact provisions out of their own Title VI regulations. By 2026, a further executive order defined "racially discriminatory DEI activities" broadly and added a new federal contracting clause backed by False Claims Act exposure, meaning a contractor found to have miscertified its compliance could face fraud liability, not just a lost contract.

The Equal Employment Opportunity Commission moved in the same direction, rescinding its longstanding affirmative action guidance and shifting its enforcement priorities toward scrutinizing race- and sex-conscious practices rather than protecting them.

Most organizations are calling what happens next a compliance decision. In the narrowest sense, it is. Legal risk changed, so the language changed. But the values question sits underneath that framing, and it is not going away just because compliance answered a different one: if the commitment was real, why did it require a favorable legal and political climate to survive?

A pattern worth naming plainly: there is a real difference between a company that changed its language because the law required it, and a company that had been waiting for permission to change it anyway. From the outside, in the first year, they look identical. Over time, they do not.

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What the vow was built to test

Wedding vows do not say "in favorable conditions." They say "in sickness and in health, for richer or for poorer." The specific pairing is not decorative. A promise that only has to hold up when things are going well was never tested at all. It only became a real commitment the day it got expensive to keep.

Organizational values work the same way — whether the value in question is diversity, safety, sustainability, or anything else a company puts in a mission statement. A value that survives only while it is legally convenient, popular with the board, and free of political cost was never a value. It was a preference that used values language while conditions allowed it.

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Reading the difference from the outside

The clearest evidence of which kind of commitment an organization actually had is showing up now, in practice rather than in press releases. Some companies moved language and substance together. IBM entered a multimillion-dollar settlement tied to Trump-era anti-DEI enforcement and narrowed programs that reviewers had flagged as favoring diverse candidates. Goldman Sachs removed race and gender from its board candidate criteria and dropped its earlier requirement that companies it took public maintain diverse boards. Across the 2026 proxy season, shareholder proposals on human capital and social issues fell by more than 30 percent, and public DEI disclosure among Fortune 500 companies declined sharply alongside them.

The rollback is not only rhetorical. It has a headcount. Since early 2023, employers have eliminated more than 2,600 positions carrying the word "diversity" or "DEI" in the title or job description, according to labor market data from Revelio Labs. DEI job postings fell 43 percent between August 2022 and July 2024, and the total number of dedicated DEI roles dropped from roughly 20,000 in 2023 to about 17,500 by 2024.

Advocacy groups and labor researchers have also pointed to a larger, harder-to-attribute pattern in the same window: an estimated 304,000 Black women lost jobs between February and April 2025, with roughly 300,000 leaving the labor force entirely in that period. Several commentators have named DEI rollbacks as a contributing factor. The available data does not cleanly separate that effect from broader economic and political pressures landing on the same population at the same time, and that uncertainty is worth stating plainly rather than smoothing over. What is not uncertain is that real people, not just program budgets, absorbed this shift.

The governance numbers are cleaner, because they measure what a company will put in writing rather than what caused what. Only about 12 percent of S&P 500 companies now disclose using diversity criteria in board appointments, down from 23 percent in 2025 and 48 percent in 2024. Across the Russell 3000, proxy filings with explicit commitments to include women and people of color in candidate pools — language modeled on the NFL's Rooney Rule — fell from 35.7 percent of filings in 2024 to 18.6 percent in 2025 and 12.4 percent in 2026. Leadership-level gender disclosure among S&P 500 companies dropped from about 86 percent in 2024 to 62.2 percent in 2026, and race and ethnicity disclosure fell to 47.6 percent. A federal civil rights agency has moved to end demographic data collection requirements that had been in place for more than sixty years.

When an organization stops measuring something, it also stops being able to prove — to itself or anyone else — what it actually did.

Other organizations chose a different path: not defiance for its own sake, but adaptation built to keep the underlying goal intact. The Colorado Department of Law has continued to build its fellowship program explicitly around its diversity commitment. State coalitions and civil rights groups are actively challenging the new executive orders in court rather than waiting to see how enforcement shakes out. Fearless Fund, after a legal challenge to its grant program for Black women founders, did not fold the program. It rebuilt around supporting women founders internationally — a structure designed to survive the exact legal attack aimed at the domestic version.

Neither response is about who made the most noise. Both are a test of whether the goal survived the shape it had to take to stay alive.

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The contrast

The pattern worth watching is not who kept the word "diversity" on the website. Words are the cheapest part of any commitment to change. The pattern worth watching is whether the underlying practice moved with the word or stayed put without it:

• Hiring: Did structured, bias-resistant hiring processes stay in place, or did the process quietly revert once nobody was tracking it anymore?
• Pay: Did pay equity reviews keep happening on the same schedule, or did they lapse the same year the language did?
• Advancement: Did sponsorship and advancement support for underrepresented talent continue at the same rate, or did it get cut alongside the budget line that used to have "DEI" in its name?
• Candor: Did leadership say anything honest internally about why the language changed, or did the explanation stop at "evolving legal landscape" and go no further?

Question for you: if someone audited your organization's actual practices today against what they were doing three years ago, would the story match the explanation you've been giving publicly?

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The mirror

You may be the leader who has to make this call, or the one watching someone else make it. Either way, the test is not whether your organization changed. Conditions changed for everyone, and no one is required to hold every position permanently regardless of new information.

The test is whether you can say, honestly and out loud, which kind of change this was. A company that says "we no longer believe this is the right approach" is taking a position it can defend. A company that lets the language quietly disappear while hoping no one asks why is not protecting itself from risk. It is avoiding the conversation entirely.

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The call

Every leader in the Revolutionary Leadership Series held their position inside a hostile institutional environment. None of them waited for the political weather to improve before deciding who they were. That is the most direct connection this series has drawn back to July's leaders, and it is not a comfortable one for most organizations to sit with.

The Reckoning is not asking you to take a side on any specific policy. It is asking whether your organization can tell the difference, honestly, between changing its mind and changing its weather report.

If you are not certain your organization could answer that question in a board meeting without flinching, that is the conversation Visionary Consulting exists to have with you.

Where Vision Meets Reality.