Summary At a Glance
- As of September 21, covered contractors must discontinue using Form CC-305.
- Section 503 AAPs and other core compliance obligations remain in effect.
- Qualifying contractors and subcontractors must file 2026 VETS-4212 Reports by September 30.
Section 503 Changes Take Effect Today
As of today, covered Federal contractors and subcontractors (collectively, “contractors”) are no longer required to use Form CC-305 to solicit applicant and employee disability status, apply the 7% disability utilization goal, or complete the related disability applicant and hiring analyses. However, written Section 503 affirmative action plans and other core obligations remain in place, including disability outreach, reasonable accommodation practices, personnel process reviews, training, recordkeeping, and annual evaluation of outreach effectiveness.
HR Works has additional resources to help employers navigate these changes, including our recent article “OFCCP Ends Disability Goal & Self Identification Requirements” and the on-demand recording of our recent webinar on this topic.
Next Steps for Employers
- Confirm that Form CC-305 has been removed from applicant and employee processes.
- Discontinue soliciting disability status from applicants. Any ongoing employee disability inquiries should be consistent with the Americans with Disabilities Act and designed with the assistance of legal counsel.
- Verify that applicant tracking and human resource information systems have been updated.
- Continue safeguarding previously collected disability information by storing it separately from general personnel records and employee medical files.
- Update Section 503 AAP content for plans beginning on or after September 21 while maintaining all remaining affirmative action obligations.
How HR Works Can Help
HR Works assists federal contractors adapting to the Section 503 changes by updating AAP content, reviewing self-identification and data-handling practices, assessing outreach and accommodation processes, and identifying necessary system, policy, and training updates.
Current clients should contact their designated AA/EEO Consultant for assistance with preparing for the changes.
Not an HR Works client? To learn more about how HR Works can support your organization, visit our website and complete a “Contact Us” form or call us toll-free at 1-877-219-9062.
VETS-4212 Filing Deadline is September 30
As a reminder, covered federal contractors and subcontractors should confirm their VETS-4212 reporting obligations and submit their 2026 reports by September 30, 2026.
Key Changes to Note
As HR Works previously reported, the federal contract or subcontract threshold increased from $150,000 to $200,000, effective October 1, 2025. Contractors and subcontractors with at least one qualifying contract of $200,000 or more are required to file one or more VETS-4212 reports, regardless of workforce size. Filing methods remain unchanged, and reports may be submitted electronically, by batch upload, or by mail or email.
How HR Works Can Help
HR Works provides VETS-4212 consultation, data cleansing, and filing. Visit our website to learn more about our Federal and State reporting services.
