The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has issued significant regulatory changes affecting federal contractors and subcontractors.
These updates modify longstanding affirmative action, disability compliance, and veteran employment requirements, potentially impacting compliance programs, recordkeeping practices, and affirmative action plans.
Organizations subject to OFCCP compliance requirements should review their policies and procedures to understand how these regulatory changes may affect their obligations under federal law.
Section 503 Disability Compliance Requirements Modified
Effective September 21, 2026
The OFCCP has finalized changes to regulations implementing Section 503 of the Rehabilitation Act, removing several requirements previously imposed on covered federal contractors, including:
- Disability self-identification invitations for applicants and employees.
- Certain disability-related applicant and hiring data collection requirements.
- Disability utilization analyses and the former 7% utilization goal.
While these requirements have been eliminated, Section 503 remains in effect. Federal contractors must continue to comply with disability nondiscrimination and affirmative action obligations under the Rehabilitation Act.
Government Source: OFCCP Section 503 Final Rule
Executive Order 11246 Regulations Rescinded
Effective October 26, 2026
The OFCCP has issued a final rule rescinding regulations that implemented Executive Order 11246, a longstanding federal contractor affirmative action and equal employment opportunity requirement.
Prior to its revocation in 2025, Executive Order 11246 required covered federal contractors to take affirmative action and prohibited discrimination based on race, color, religion, sex, sexual orientation, gender identity, and national origin.
The new rule removes the associated regulatory framework contained in 41 CFR Part 60-1 and related provisions.
Government Source: EO 11246 Rescission Final Rule
VEVRAA Compliance Updates for Federal Contractors
Effective September 21, 2026
The OFCCP has also revised regulations implementing the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). Key changes include updates to coverage thresholds and the removal of references to Executive Order 11246.
Despite these revisions, veteran nondiscrimination and affirmative action requirements remain in effect for covered federal contractors and subcontractors.
Government Source: VEVRAA Final Rule
What Federal Contractors Should Review
In response to these OFCCP regulatory changes, employers should consider reviewing:
- Affirmative action plans and supporting documentation.
- Disability self-identification processes and recordkeeping practices.
- Recruiting, hiring, and applicant tracking procedures.
- VEVRAA compliance requirements and veteran hiring obligations.
- Equal employment opportunity (EEO) and nondiscrimination policies.
Because federal contractor compliance obligations vary based on contract type, workforce size, and organizational circumstances, employers should consult qualified legal counsel to determine how these changes apply to their specific operations.
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Sources
This article is based on information published by the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) and related federal regulatory resources:
- OFCCP Final Rule: Modifications to the Regulations Implementing Section 503 of the Rehabilitation Act of 1973, as Amended
- Federal Register PDF: Section 503 Final Rule
- OFCCP Final Rule: Rescission of Executive Order 11246 Implementing Regulations
- OFCCP Final Rule: Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) Regulations
- Electronic Code of Federal Regulations (eCFR): 41 CFR Part 60-741
Affirmative Action and Nondiscrimination Obligations of Contractors and Subcontractors Regarding Individuals with Disabilities
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