Sounds like your employer is trying to comply, although that’s no guarantee they won’t get hit with a penalty in one form or another. What’s next, will they just start firing anyone not in compliance?
They’ve already threatened penalties if we give personal references to several people laid off due to skill mismatches with remaining work. All they can do is call the company employment line and get a verification of dates of employment. If the remainder give personal references, we can be reprimanded or fired.
It’s all for legal CYA.