How to adhere to contract requirements on civil immigration enforcement

In 2025, King County Council passed updates to King County Code (KCC) 2.15 focused on new and expanded civil rights protections and non-discrimination provisions  regarding immigration status and citizenship, and additional requirements for contractors . 

King County Ordinance 19963

King County Ordinance 19977

Additionally, King County now prohibits its contractors from complying or cooperating with civil immigration enforcement, absent a judicial warrant or court order.

“Civil immigration enforcement operation” means an operation that has as one of its objectives the identification or apprehension of a person or persons in order to investigate them for a violation of immigration laws and subject them to one or more of the following:

Civil immigration detention;

Removal proceedings; or

Removal from the United States.

United States Immigration and Customs Enforcement (ICE)

United States Customs and Border Protection (CBP)

United States Citizenship and Immigration Services (USCIS)

Potentially other federal agency officers, agents, or representatives

KCC 2.15 requires both King County and all its contractors to make reasonable efforts to provide free interpretation and translation services to limited-English-proficient persons. King County agencies shall provide support to contractors to meet the requirements of this section. Contractors may consult with the King County employee listed in relevant contracts about support to meet language access requirements in their contracts. DCHS will review individual actions to assess compliance with KCC 2.15.

Contractors can show King County they are a “making good faith effort” to meet the KCC 2.15.050 requirements of their specific contracts by acting on the minimum expectations below:

1. Post signs where it is easy for all to see and understand, clearly showing public areas and equipment and restricted areas and equipmedfnt (nonpublic).
2. Update (or create) operational policies and procedures, making sure that your employees are aware of and know how to comply with these contract requirements. Contractor’s operational policies and procedures shall be submitted to King County upon request.
3. Ensure that your entity and its agents follow all anti-discrimination provisions and relevant state and federal laws as required in your contracts.

DCHS will review individual actions to assess compliance with KCC 2.15.

When a staff member inadvertently gives a person permission or the ability to enter a private location, or view information, or use a system. DCHS will review individual actions to assess compliance with KCC 2.15.

Contractors are expected to begin taking steps to comply with these requirements within six months of a signed contract. Contractors are expected to begin taking steps to comply with these requirements as soon as a contract is signed. DCHS recognizes that some operational changes may require implementation time and will provide guidance and technical assistance to support compliance. 

King County may review compliance through existing contract monitoring activities, including site visits and program reviews. Compliance may be assessed during routine monitoring activities or when following up on a compliance concern.

Contractors should maintain documentation demonstrating compliance, by taking one or more of the following steps:

• Policies and procedures;
• Staff training records;
• Signage identifying public and nonpublic spaces, when applicable;
• Records of requests for access to nonpublic facilities, databases, equipment, or records; or
• Documentation of notifications provided to King County regarding these requests.

Notice of all attempts or requests by civil enforcement officers to access nonpublic facilities or databases shall be immediately sent to King County in accordance with the terms of the Contract.

Permission given to ICE, CBP, USCIS, or any other federal agency officers, agents, or representatives to access any such a facility, real or personal property, Equipment, nonpublic database, or nonpublic portion of an otherwise public database without a judicial criminal warrant, subpoena, or court order may only be provided with the prior express, written approval of the Contract Manager as identified in Agiloft.

Never interfere with or obstruct an immigration law enforcement officer. If an immigration enforcement official forces entry into an area where they are not permitted (including in non-public areas of a contractor’s facility or workspace), contractors should contact their Contract Manager.

1. Update (or create) operational policies and procedures, making sure that your employees are aware of and know how to comply with these contract requirements. Contractor’s operational policies and procedures shall be submitted to King County upon request.
2. Ensure that your entity and its agents follow all anti-discrimination provisions and relevant state and federal laws as required in your contracts.

King County is currently assessing state, local, and federal policies.

Public spaces include public hallways, public elevators, lobbies, and/or counters where contracted providers serve the public, and most reception areas during business hours.

Any area of a contractor's facility, used to provide services under the county contract, that is not generally open and accessible to the general public, but instead requires the contractor’s permission for admittance to that area is not a public space. This includes databases used to provide services under the county contract that are not accessible to the public.

KCC 2.15 has expanded to include funding for providers. King County is making funds available for contracted human services providers that need these services. Please contact your Program Manager for more information.