By Mark Adams
Federal contractors have two affirmative action compliance items to keep in mind this summer. OFCCP has renewed the disability self-identification form used for Section 503 compliance, and the annual VETS-4212 reporting period is now underway.
OFCCP Renews Section 503 Self-Identification Form:
The Office of Federal Contract Compliance Programs (OFCCP) has renewed its “Voluntary Self-Identification of Disability Form (CC-305)”. Covered federal contractors use the form to give applicants and employees an opportunity to voluntarily identify as an individual with a disability.
The requirement comes from Section 503 of the Rehabilitation Act, which prohibits disability discrimination by covered federal contractors and requires affirmative action for qualified individuals with disabilities.
Contractors should take this opportunity to make sure the current CC-305 is being used throughout their recruiting and employment processes, including within applicant tracking and onboarding systems. Contractors should also remember that the self-identification obligation does not end at hire. Employees must periodically be given another opportunity to self-identify, along with a reminder during the intervening period that they may voluntarily update their disability status.
You can find the updated form by clicking here.
VETS-4212 Reporting Period Is Open:
The Department of Labor’s Veterans’ Employment and Training Service has also opened the 2026 VETS-4212 reporting period. Reports may be submitted between August 1 and September 30, 2026.
Generally, federal contractors and subcontractors with a covered federal contract or subcontract of $150,000 or more are required to file. The report provides DOL with information about the contractor’s workforce and new hires, including the number of protected veterans.
This year’s filing is also a useful reminder that the federal contractor compliance landscape did not disappear with the revocation of Executive Order 11246. Although the affirmative action requirements involving women and minorities have changed significantly, the separate requirements covering individuals with disabilities under Section 503 and protected veterans under VEVRAA remain in place.
What Should Contractors Do Now?
Check the version of CC-305 being used by your organization, particularly if the form is embedded in an applicant tracking or onboarding system. At the same time, contractors subject to VETS-4212 should begin pulling together their workforce and protected veteran data so the September 30 filing deadline does not become a last-minute project.
Covered federal contractors and subcontractors can log into the portal now by clicking here.
For federal contractors adjusting to the changes of the past year, these are two compliance obligations that should remain firmly on the checklist.