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Title VII Compliance Checklist for Foreign-Owned Employers

Use this Title VII compliance checklist for foreign-owned U.S. employers with India or Canada ties: rules, deadlines, damages caps and recent changes.

Last reviewed October 27, 2026 · 3 min read · General information, not legal advice

General information only, not legal advice. CPA Tax Payroll and Accounting Corp is a CPA firm, not a law firm. Laws change: confirm with the official source or a licensed attorney before you act. Read the full notice.

This Title VII compliance checklist turns the Civil Rights Act's job rules into steps for a U.S. employer owned from India or Canada. It builds on the overview and marks what is only proposed as of October 27, 2026.

What does Title VII require?

AreaRule
DiscriminationNone in hiring, firing, pay, promotion, training, benefits or other terms of work tied to race, color, religion, sex or national origin.
RetaliationNone against anyone who opposes a practice they reasonably judge unlawful or files a charge.
Job adsBarring a narrow job-qualification exception, no stated preference or limit tied to a protected trait.
ReligionAccommodate sincere practice unless it is a substantial burden in the overall context of the business (Groff v. DeJoy, June 29, 2023).
PregnancyTreat like other temporary limits on capacity to work.
HarassmentReasonable prevention and prompt correction can decide liability; supervisor harassment ending in a job action is automatically the employer's.
Notice and recordsDisplay the EEOC notice. Hold personnel records for 1 year, relevant ones until a charge is resolved.

Key numbers and dates

ItemFigureYear
Charge deadline180 days; 300 where state or local law applies (EEOC: 300 in Illinois)2026
Suit after EEOC notice90 daysstatute
Poster fineUp to $698 per offensesince September 30, 2025
Damages cap by employer size (employees) U.S. dollars, fixed by statute
15 to 100$50,000
101 to 200$100,000
201 to 500$200,000
More than 500$300,000

Source: 42 U.S.C. 1981a(b)(3)

Recent and pending changes

  • January 22, 2026: the EEOC voted to rescind its 2024 harassment guidance, 2-1; the statute is unchanged.
  • October 26, 2026: DOL's rescission of its Executive Order 11246 rules took effect.

Title VII compliance checklist: the Fox River Fair-Treatment Pass

We call this yearly set the Fox River Fair-Treatment Pass.

  1. Count employees weekly against the 15-employee line.
  2. Read job ads and interview scripts for nationality or visa preferences.
  3. Write a complaint route and log each complaint.
  4. Review religious and pregnancy requests against the standards above.
  5. Have a second person review any firing after a complaint.
  6. Display the EEOC notice; keep personnel records for 1 year.
  7. Train managers; keep demographic data out of decisions.

Common mistakes

  • No complaint route, or sitting on a complaint.
  • Retaliating through schedule changes or extra scrutiny.
  • Denying a Sabbath or dress request when the cost is small.
  • Ads that prefer visa workers or one nationality.
  • Discarding applicant files before 1 year.

When to bring in an attorney

  • An Illinois Department of Human Rights or EEOC charge.
  • Harassment complaints involving an owner or manager.
  • A firing soon after a complaint or accommodation request.

How we can help

We handle the U.S. payroll, tax and accounting side for Aurora-area employers, working with your attorney, Canadian CPA or Indian CA. See payroll and employer compliance and bookkeeping and accounting.

Frequently asked questions

Does Title VII cover a business with fewer than 15 employees?

No, though the Equal Pay Act (part of the FLSA) and state or local law may.

How long does a worker have to file a charge?

180 days, or 300 where state or local law applies. The EEOC lists 300 in Illinois.

Can a job ad prefer applicants from India or Canada?

The EEOC says ads preferring a particular country can be discrimination; ask an attorney about the narrow exception.

Is the EEO-1 still required?

The rule is still on the books, but rescission was proposed July 23, 2026. Check the EEOC.

Official sources

This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.