OFCCP Seeking Formal Approval To Revise Agency Complaint Forms

January 15, 2026

What's New

The Office of Federal Contract Compliance Programs (OFCCP) has submitted a formal proposal to the Office of Management and Budget (OMB) for approval to 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.

In July of 2025, OMB approved similar revisions to the forms on an emergency basis. At the time, complaints filed under E.O. 11246, Section 503 of the Rehabilitation Act, and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act all shared the same complaint form, which still permitted individuals to file complaints on the basis of characteristics such as race, ethnicity, and sex, which no longer fell under OFCCP’s jurisdiction.

What It Means

OFCCP’s formal extension request is the last step in the process mandated under the federal Paperwork Reduction Act. The changes in question reflect the rescission of E.O. 11246 and confirm that individuals may no longer file with OFCCP discrimination 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 You Should Do

CWC intends to submit written comments to OMB, which are due by February 2, 2026. OFCCP’s proposed changes to the complaint forms will also be a featured topic at CWC’s upcoming Workplace Policy Conference, which will be held virtually on March 18-19, 2026.

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