Disability Status Resurveys Are Still Required

Disability self-identification has been in the spotlight lately, especially for federal contractors watching potential changes to Section 503 of the Rehabilitation Act of 1973 (Section 503). However, in this changing landscape, employers cannot afford to be reactive. Whether you’re resurveying because you must or because it’s simply smart business, one principle holds true: current data is always better data.

If you’re a federal contractor covered by Section 503, you are currently required to invite employees to voluntarily self-identify as having a disability the first year you’re subject to the requirements and then at least once every five years, with at least one reminder in between that they can update their status at any time. For many federal contractors, 2025 or 2026 was a required resurvey year.

Many contractors have asked whether they should conduct a resurvey because, in mid-2025, the Office of Federal Contract Compliance Programs (OFCCP) proposed rule changes and information-collection updates that would eliminate the required disability self-ID survey and associated utilization goals. As of now, however, these are proposals and the existing requirements still apply. Accordingly, federal contractors and subcontractors subject to Section 503 should not delay required disability resurveys while these rule changes are pending,

Keep in mind that the current Section 503 regulations also allow more frequent workforce surveys. And many federal contractors have taken this approach, often allowing employees to update their disability status at least annually or even on demand via a self-serve HRIS option. These best practices can also continue while OFCCP considers rule changes.

Conducting a resurvey now can be particularly beneficial, ensuring you have the most current workforce data if the proposed Section 503 changes are finalized. While the data needs to be maintained confidentially, HR can use aggregated information to support staffing, training, and accessibility decisions. Collecting the data early in 2026 also allows you to better respond to evolving state or federal requirements, so you won’t be scrambling to rebuild data and processes if requirements change again. Finally, because disability status can change over time, old data becomes inaccurate quickly. Employees may develop new disabling physical conditions or mental health challenges. Others may feel more comfortable disclosing as the workplace culture changes.

Done well, a disability resurvey also sends a very human message:

• “We see disability as part of inclusion.”
• “We’re prepared to invest in accessibility.”
• “We want to understand your needs and remove barriers.”

Pair the resurvey with education about what counts as a disability and you can:

• Normalize self-identification
• Increase trust in HR and leadership
• Encourage employees to request the accommodations they need to be successful.

On the analytics side, disability data fills a critical gap in your company picture, allowing you to examine:

• Representation of employees with disabilities at different levels.
• Pay equity, promotion, and retention outcomes for employees with disabilities.

The result: a more honest understanding of where you’re doing well, and where you need to act.

Best Practices for Running a Disability Resurvey

To get the most out of a resurvey, legally and culturally, keep these principles front and center:

1. Reinforce that it’s voluntary and confidential. Make clear that employees can opt out and that the information will not be used to make employment decisions. This mirrors regulatory expectations to keep disability self-ID voluntary, confidential, and separate from personnel decisions.
2. Use approved or vetted language. Contractors must use the current OFCCP-approved form (or its required language in an approved format).
3. Educate, don’t just collect. Explain what counts as a disability, why you’re asking, and how the data will be used. Many people don’t realize their conditions qualify, which depresses your response rates and undercuts your analytics.
4. Tie it to visible action. Link the resurvey to concrete initiatives such as accessibility projects. When employees see that sharing their data leads to real improvements, trust and participation go up.
5. Plan your cadence. At minimum, follow the five-year requirement while the OFCCP rule change is pending. Many organizations choose to resurvey more frequently. This could be every 2–3 years or annually to keep data fresh and response rates high.