OFCCP Proposes Eliminating Disability Self-Identification and Analysis Requirements

July 1, 2025

What's New

The Office of Federal Contract Compliance Programs (OFCCP) has published two Notices of Proposed Rulemaking (NPRM), which, if approved, would modify agency regulations implementing the nondiscrimination and affirmative action requirements of Section 503 of the Rehabilitation Act (Section 503) and Section 4212 of the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA).

While the VEVRAA NPRM is largely administrative in nature—and aligns with a corresponding proposal connected to rescinding Executive Order 11246 regulations—OFCCP’s proposed Section 503 changes are significant. OFCCP proposes to remove:

any requirement to solicit disability status from applicants or employees;
the need to conduct a disability utilization analysis; and
tracking the disability applicant and hire metrics used to assess Section 503 outreach.

What It Means

It’s important to emphasize that these are proposed rulemakings and there is no immediate impact on contractors’ Section 503 and VEVRAA compliance requirements. Under the Administrative Procedure Act, interested parties will have until September 2, 2025, to submit comments to OFCCP, and CWC intends to file comments.

What You Should Do

We encourage CWC members’ feedback on OFCCP’s proposals, which we will consider and incorporate as appropriate into CWC’s comments. OFCCP’s proposals will also be a featured topic at CWC’s upcoming DC Member Roundtable to be held in Washington, DC, on Thursday, July 31.

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OFCCP Proposes Eliminating Disability Self-Identification and Analysis Requirements

Jul 1, 2025 – OFCCP has proposed eliminating long-standing disability compliance requirements, including self-identification, utilization analyses, and applicant tracking. The agency will be accepting public comments for 60 days.

Section 503 of the Rehabilitation Act

Jun 17, 2025 – A high level summary of Section 503 of the Rehabilitation Act of 1973.

OFCCP Issues Last-Minute Extension on Section 503, VEVRAA, and E.O. 11246 Comment Deadlines

Sep 3, 2025 – OFCCP has issued a last-minute 15-day extension for submitting comments on its proposed elimination of longstanding disability compliance requirements – including self-identification, utilization analyses, and applicant tracking.

CWC Recommends OFCCP Retain Form CC-305 On A Voluntary Basis

Oct 30, 2025 – CWC has filed comments with OFCCP urging it to consider alternatives to its proposed elimination of the Voluntary Self-Identification of Disability Form (Form CC-305).

CWC Urges OFCCP To Consider Alternatives To Section 503 Rulemaking

Sep 25, 2025 – CWC has filed comments with OFCCP urging it to consider alternatives to its proposed revisions of nondiscrimination and affirmative action regulations under Section 503 of the Rehabilitation Act.

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