The Equal Employment Opportunity Commission’s (EEOC) six-year-old systemic discrimination enforcement program is building steam, fueled by more aggressive investigative tactics and litigation strategies that are creating new challenges for employers.

In adopting its 2012-2016 strategic plan in February, the EEOC reiterated its emphasis on systemic cases. Instead of focusing on individual charges of discrimination, the agency is using such claims to launch broad investigations with the goal of uncovering similar cases that can be combined into pattern and practice lawsuits.