On August 21, 2026, the Office of Federal Contract Compliance Programs (OFCCP) published final rules changing regulations implementing Section 503 of the Rehabilitation Act (Section 503), the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), and Executive Order 11246. Federal contractors should review these final rules and adjust their programs appropriately.
These developments have been in progress since the beginning of 2025 when President Trump issued an executive order that revoked Executive Order 11246. Then, on July 1, 2025, the OFCCP published regulatory proposals to rescind Executive Order 11246 regulations and revise regulations implementing Section 503 and the VEVRAA to remove related references.
Importantly, these final regulations do not eliminate affirmative action obligations under Section 503 and VEVRAA, nor do they eliminate discrimination prohibitions under Title VII of the Civil Rights Act. However, covered contractors’ compliance obligations, especially under Section 503, have some notable changes.
Section 503
Section 503 of the Rehabilitation Act of 1973 prohibits covered federal contractors and subcontractors from discriminating against individuals with disabilities, and requires contractors to take affirmative action to recruit, hire, promote and retain them. Current regulations require employers to invite employees and applicants to voluntarily self-identify as individuals with disabilities and maintain a goal of having at least seven percent of workers as individuals with disabilities.
The OFCCP’s final rule on Section 503 eliminates the requirement for covered federal contractors to invite applicants and employees to self-identify as individuals with disabilities, eliminating Form CC-305 — the Voluntary Self-Identification of Disability form — and related data collection requirements. The rule also eliminates the seven percent utilization goal for individuals with disabilities.
The OFCCP concluded that the employer requirement to invite applicants and employees to self-identify as individuals with disabilities conflicts with the plain text of the Americans with Disabilities Act (ADA).
This final rule also eliminated cross references to Executive Order 11246 and codified the inflationary adjustment to the basic coverage threshold, which increased from $15,000 to $20,000 on October 1, 2025.
The final rule doesn’t eliminate other Section 503 affirmative action obligations. Covered contractors must continue to comply with all other Section 503 requirements and should consult with legal counsel if they have questions about their obligations.
The Section 503 final rule takes effect on September 21, 2026.
VEVRAA
Like Section 503, VEVRAA prohibits covered federal contractors and subcontractors from employment discrimination against protected veterans and requires these employers to take affirmative action to recruit, hire, promote and retain these veterans, including inviting applicants for employment to self-identify as protected veterans at both the pre-offer and post-offer stage.
Unlike the Section 503 final rule, the OFCCP’s final VEVRAA rule doesn’t eliminate the self-identification provision, data collection requirements or make other significant substantive changes. Instead, the final rule eliminates cross references to Executive Order 11246 and codifies the jurisdictional threshold adjustments made for inflation on October 1, 2025, which increased the threshold for VEVRAA basic coverage to $200,000 and the written affirmative action plan requirement for employers with 50 or more employees to $200,000 — both up from $150,000.
The VEVRAA rule takes effect on September 21, 2026.
Executive Order 11246
Lastly, the OFCCP published a final rule to officially rescind the implementing regulations of the now-revoked Executive Order 11246. This rule takes effect on October 26, 2026.
Though the OFCCP has not been enforcing Executive Order 11246 since it was revoked, the Equal Employment Opportunity Commission’s (EEOC) “Know Your Rights: Workplace Discrimination is Illegal” poster still references the order. With the order’s implementing regulations officially scrapped, the EEOC may update its workplace poster to remove references to the order. Employers should monitor the EEOC’s website for updates.
Employer Takeaways
Federal contractors should review the OFCCP’s final rules and prepare to update their practices when they take effect. Contractors should review their Section 503 affirmative action plans and processes and consult with their legal counsel to help ensure they comply with the new regulations, including removal of the self-identification process. At the same time, contractors must continue to comply with their remaining obligations under Section 503 and VEVRAA.
Employers should also monitor the EEOC’s website for an update to the “Know Your Rights” poster.
James W. Ward, J.D., Employment Law Subject Matter Expert/Legal Writer and Editor, CalChamber
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