OFCCP Revises Discrimination Complaint Forms Without Opportunity for Comment

July 16, 2025

What's New

OFCCP has revised its Complaint of Employment Discrimination Involving a Federal Contractor or Subcontractor form (CC-4) and Pre-Complaint Inquiry for Employment Discrimination Involving a Federal Contractor or Subcontractor form (CC-390). OFCCP uses the forms to process employment discrimination allegations against federal contractors.

The changes reflect the rescission of E.O. 11246 and confirm that applicants and employees may no longer file complaints on the basis of race, color, religion, sex, sexual orientation, gender identity, or national origin, or allege they were retaliated against for asking about, discussing, or disclosing compensation.

OFCCP asked the Office of Management and Budget to approve the revisions on an emergency basis, reasoning that the Department of Labor has not been able to process any disability or veteran complaints because E.O. 11246, Section 503 of the Rehabilitation Act (Section 503), and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) share the same complaint form.

What It Means

The revised CC-4 and CC-390 are available immediately for filing employment discrimination complaints. OFCCP recently announced that the agency will resume processing Section 503 and VEVRAA complaint investigations as normal, including any new complaints filed since January 21, 2025.

What You Should Do

If your organization undergoes a Section 503 or VEVRAA complaint investigation, the agency will likely request a copy of your Section 503 and/or VEVRAA affirmative action plans (AAPs). Organizations should ensure that those AAPs are in place for their 2025 cycle.

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