Shifts in Corporate Responses to DEI: A Closer Look

The first 100 days of the second Trump administration have featured an all-out campaign against perceived “unlawful” corporate DEI practices. A recent Bloomberg analysis, in addition to HRPA’s recent CHRO Survey, provide a closer look into how companies have responded.

Trump’s Executive Order (EO) targeting private sector DEI practices ushered in a new wave of course corrections on DEI, with at least 37 large publicly traded companies making substantive changes, beyond merely changing language or titles.

• While previous changes were largely cosmetic – changing public-facing language, for example, the EO triggered more substantive changes such as ending hiring goals, representation targets, supplier diversity goals, and tying goals to executive pay, according to Gravity Research.

• CHROs surveyed by HRPA reported decreases in public quantitative goals, tying DEI metrics to executive pay, and participation in outside culture surveys.

Reduction in public disclosures: There has been a marked decrease in public disclosure of diversity data. 

• In 2024, for example, 100% of S&P 500 companies publicly disclosed at least one quantitative measure of board diversity. In 2025, that number decreased to 75%, according to DiversIQ.

• Over half of CHROs surveyed by HR Policy indicated an intent to reduce DEI disclosures on public websites, in public filings, and in sustainability reports.

Pro-ESG shareholder proposals drop: Shareholder proposals in support of ESG initiatives declined by more than a third in 2025, according to a report by shareholder advocacy group As You Sow.

• Conversely, while anti-DEI shareholder proposals have increased, they are rarely successful. Several recent high-profile votes delivered resounding “No’s” to such proposals. 

Takeaways:

• Company responses to the new, hostile DEI environment vary across a wide spectrum that approximates a bell curve. Most companies are making smaller, strategic, behind-the-scenes shifts to reduce risk while remaining committed to DEI principles in alignment with long-standing company values and culture.

  • A much smaller percentage of companies are either rescinding all or nearly all DEI commitments or, at the other extreme, doubling down on their DEI efforts.

• It remains unclear how the Trump administration will define “illegal DEI,” and any such definition will have to be upheld in court to actually change the law. For now, the risks remain largely reputational, albeit significantly so.

What’s next: According to the EO, the Attorney General is expected to publish a report in May highlighting several companies that the administration considers “worst offenders” when it comes to DEI. 

• The report will also recommend regulatory and enforcement measures and could provide a clearer blueprint for what employers can expect to face related to government oversight.