Affirmative action employers may have noticed the looming expiration date on their Form CC-305 Voluntary Self-Identification of Disability. The form, mandated by the Office of Federal Contract Compliance Programs (OFCCP) for use by Federal contractors and subcontractors meeting affirmative action plan thresholds, displays an OMB Control Number of 1250-0005 and expires on April 30, 2026.
What happens on May 1st? Employers should keep using the current form. The Labor Department issued a Notice and request for comments in the Federal Register seeking to extend this form without change. The comment period remains open through May 26, 2026, after which OMB will determine whether to approve the document to continue without change. Until that determination is made, affirmative action employers remain subject to use of this form in accordance with Section 503 of the Rehabilitation Act regulations.
Form CC-305 is used at four employment stages to solicit voluntary self-identification of disability status from applicants and employees:
- Application or consideration for employment; pre-offer
- Onboarding; post-offer
- At five-year intervals to all company employees, with at least one reminder to employees in the intervening years that they may update their disability status
- Any time an employee indicates a desire to update their disability status
HR Works, Inc.’s AA/EEO specialists will post an announcement and notify clients when OMB makes its determination and OFCCP provides a new Form CC-305. Current clients should reach out to their dedicated Consultant with any questions.
In the same edition of the Federal Register, the Labor Department posted a Notice and request for comments asking OMB to extend document 1250-0004 OFCCP Recordkeeping Requirements under the Vietnam Era Veterans’ Readjustment Assistance Act without change. This document is also set to expire on April 30, 2026, with the comment period now open through May 26, 2026. Affirmative action employers should continue their VEVRAA compliance activities without change until an OMB determination is made.
Document 1250-0004 covers recordkeeping requirements such as soliciting veteran status from applicants and employees, developing an annual affirmative action program, engaging in internal auditing and reporting, collecting and analyzing information about veteran hiring and application rates, establishing a veteran hiring benchmark, posting jobs with the local ESDS, and notifying subcontractors of a company’s affirmative action status. HR Works will also keep you informed of any updates to this form.
