by Mark Adams
As autumn approaches, it’s time for federal contractors and subcontractors to turn their attention to a key annual compliance obligation: filing the VETS-4212 Report under Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). This reporting requirement serves as a cornerstone of the government’s efforts to ensure equal employment opportunities for protected veterans and remains a critical part of a contractor’s overall affirmative action responsibilities.
Who is covered? The requirement applies to all federal contractors and subcontractors with a single contract of $150,000 or more. This threshold was increased in 2015 from $100,000, meaning smaller contracts are no longer covered. Importantly, both prime contractors and subcontractors are responsible for compliance, regardless of industry. Employers with multiple establishments must file a report for each location, or they may choose to submit a consolidated report if appropriate.
The reporting process. Each year, covered employers must provide the U.S. Department of Labor’s Veterans’ Employment and Training Service (VETS) with data on the number of employees and new hires who are protected veterans. The data reflects a 12-month period ending on a date of the employer’s choosing between July 1 and August 31. The report must be submitted by September 30. Employers can complete the filing electronically through the DOL’s dedicated online portal at https://www.dol.gov/agencies/vets/programs/vets4212. The system allows for direct entry using a web form, or for larger employers with multiple sites, batch upload files can be used to streamline reporting.
Penalties for non-compliance. Failing to file the VETS-4212 Report is not a minor oversight—it can have significant consequences. The Department of Labor may recommend the suspension or cancellation of federal contracts and could declare a contractor ineligible for future government business. In addition, the Office of Federal Contract Compliance Programs (OFCCP) frequently checks whether employers are current with their VETS-4212 filings during compliance evaluations. Missing reports can lead to audit findings and broader scrutiny of a contractor’s affirmative action program.
Practical takeaways for HR professionals. For HR and compliance leaders, Section 4212 reporting is not just a compliance requirement—it’s a chance to ensure your data systems are capturing critical information. Now is the time to review HRIS or applicant tracking systems to confirm they can track veteran hiring and employment data accurately. Work with government contracts, HR, and IT teams to verify that the data you will submit aligns with DOL reporting fields. HR should also coordinate with affirmative action program administrators to ensure reporting is consistent across all compliance areas. Finally, filing early—rather than waiting until late September—reduces stress and ensures that any technical or data-quality issues can be resolved in time.
Bottom line: Filing the VETS-4212 is both a compliance safeguard and a public demonstration of your organization’s commitment to veteran employment. By preparing early, ensuring accurate data collection, and training staff on the process, HR leaders can avoid penalties, reduce audit risk, and reinforce the organization’s reputation as a federal contractor that values equal opportunity.