What Federal Contractors Need to Know about VEVRAA and Section 503 today

Disclaimer: Effective 9/21/2026, the regulations implementing Section 503 of the Rehabilitation Act have changed, including that use of the Form CC-305 previously required for collection of voluntary disability status data from employees and applicants must be discontinued. Any disability inquiries must comply with the Americans with Disabilities Act and applicable state or local law.

Changes to federal affirmative action requirements have created questions for many federal contractors regarding their ongoing compliance obligations. While Executive Order 11246 has been revoked, it is important to understand that this action did not impact either Section 503 of the Rehabilitation Act or the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).

Both Section 503 and VEVRAA are federal statutes enacted by Congress, not executive orders, and they remain fully enforceable regardless of changes in presidential administrations. Although the Office of Federal Contract Compliance Programs (OFCCP) has not initiated new compliance audits under these programs, the agency continues to investigate discrimination complaints and enforce contractor obligations.

With these requirements in full effect, it is important for contractors to stay up to date with the requirements. Below are some recent updates to be aware of.

Reporting Thresholds

Effective October 1, 2025, the jurisdictional threshold for VEVRAA compliance increased from $150,000 to $200,000. As a result, federal contractors and subcontractors with contracts of $200,000 or more must comply with VEVRAA’s nondiscrimination and affirmative action requirements, including the development and maintenance of a written affirmative action plan. The same thresholds will apply for the required annual VETS-4212 report.

The basic coverage threshold for Section 503 has increased from $15,000 to $20,000. A written AAP for individuals with disabilities is required for contractors and subcontractors with at least 50 or more employees, and a single contract of $50,000 or more.

OFCCP

OFCCP remains the agency tasked with enforcement of Section 503 and VEVRAA. While the White House has proposed defunding the agency in its FY 2027 budget proposal, with plans to move Section 503 and VEVRAA enforcement to a new Office of Civil Rights within the Department of Labor, it is important to remember that this is just proposed.

There have also been updates to leadership at OFCCP. Ashley Romanias, the second leader of OFCCP in President Trump’s second term, left the agency in May. Romanias’ replacement as director at the OFCCP is Kenneth Wolfe, who is now listed in that role on the DOL’s website. He has been serving as director of the DOL’s Center for Faith, an office created by the Trump administration in 2025 pursuant to an executive order.