CWC Files Comments With OMB Supporting Changes To OFCCP Complaint Form

February 12, 2026

What's New

CWC has filed written comments with the White House Office of Management and Budget (OMB), supporting the Office of Federal Contract Compliance Programs’ (OFCCP) recent request to formally revise the agency’s 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 simply 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.

What It Means

OMB had already approved the revisions on an emergency basis last July, clearing the way for OFCCP to resume disability- and veteran-related complaint investigations under Section 503 of the Rehabilitation Act (Section 503) and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). OMB’s approval at this point is mostly a formality, and CWC’s comments acknowledge that given the rescission of E.O. 11246, OFCCP’s revisions will provide clarity to applicants, employees, and contractors alike.

What You Should Do

As a reminder, if your organization undergoes a Section 503 or VEVRAA complaint investigation, the agency will likely request a copy of your disability and/or veteran affirmative action plans. Organizations should ensure that those plans are in place for their 2026 cycle.

RELATED CONTENT

Subscribe to CWC's Updates and Events

CLICK TO SIGN UP