On Tuesday, February 3, 2026, H.R.7148 was signed by President Trump, allocating funding to the Office of Federal Contract Compliance Programs (OFCCP). With the OFCCP receiving new funding, federal contractors and subcontractors should prepare for a period of renewed activity and regulatory developments. Below, we break down the key changes and expectations, highlighting why it’s more important than ever to maintain compliance with Section 503 and VEVRAA Affirmative Action Programs (AAPs).
Continued Investigation of Complaints
Employers should anticipate ongoing investigations into discrimination and compliance complaints. The OFCCP’s increased resources mean that unresolved cases may be revisited, and new complaints could be processed more efficiently. Staying proactive in addressing workplace concerns and maintaining thorough documentation will be crucial.
Final Rules on Key Regulatory Changes
Several significant regulatory updates are on the horizon:
- Rescission of the IWD Self-ID Form: The OFCCP is expected to publish a final decision on the elimination of the current self-identification form for Individuals with Disabilities (IWD). Employers should monitor new guidance and be ready to update their processes accordingly.
- Removal of Disability Metrics from Section 503 AAPs: The OFCCP has proposed and should soon be publishing a Final Rule on removing the requirement to track and report disability-related metrics within Section 503 AAPs. This change, if instituted, will affect how contractors measure and report progress toward disability inclusion goals.
- Housekeeping on Section 503 & VEVRAA Regulations: Updates are anticipated to ensure the enforceability of Section 503 and VEVRAA regulations without the foundational Executive Order 11246 rules. Clarifying these regulations will pave the way for the OFCCP to resume full enforcement activity.
Resumption of VEVRAA Audits
The OFCCP has requested OMB approval to continue the VEVRAA data collection in its current form, signaling that audits under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) may soon resume. Contractors should ensure their veteran-related data and documentation are up to date and ready for review.
Contractor Portal Certification
Recent clarity regarding the OFCCP’s funding coupled with low staffing levels at the agency may spark reinstatement of contractor portal certification as an enforcement mechanism. Employers should be prepared to certify their compliance status through the portal, monitoring agency publications for announcements and timeframes.
Heightened Importance of Compliance
All these developments underscore the need for rigorous compliance with Section 503 and VEVRAA AAPs, as well as their implementation requirements. Employers should:
- Review and update AAPs to reflect the latest regulatory changes.
- Train HR and compliance teams on affirmative action requirements.
- Maintain thorough records to demonstrate compliance during audits or investigations.
Staffing Challenges May Slow Progress
Despite increased funding, the OFCCP’s ability to make rapid progress is hampered by a lack of staff following last year’s layoffs. While this may delay some enforcement actions, it should not be seen as an opportunity to relax compliance efforts. Staying ahead of requirements remains the best strategy.
Next Steps for Employers
With the OFCCP’s renewed focus, now is the time to review your practices and ensure you’re prepared for what’s ahead.
- Monitor regulatory updates and be ready to adapt policies and procedures.
- Ensure all AAPs are current and compliant with Section 503 and VEVRAA.
- Self-audit alignment between company practices and regulatory requirements to avoid being caught unaware in an OFCCP audit or investigation.
- Don’t let staffing shortages lull you into complacency—OFCCP’s renewed funding means enforcement will continue.
How HR Works Can Help
For over 30 years, HR Works has been a trusted provider of audit-ready affirmative action plans (AAPs) to employers nationwide. We offer the precise level of support that you need, all while keeping you updated on the ever-changing compliance requirements.
To learn more about our services, contact us today.
