Should Contractors Keep Using OFCCP’s Disability Self-ID Form If It Expires?

April 27, 2026

What's New

The official OFCCP disability self-identification form, Voluntary Self-Identification of Disability (CC-305), is set to expire on April 30, 2026. OFCCP currently requires federal contractors to use this form to invite applicants and employees to voluntarily self-ID disability status. OFCCP has asked the White House Office of Management and Budget (OMB) to extend its authorization to use the current form while it considers rules that could change the self-ID requirement. Several CWC members have asked what the expiration means in practice, particularly given OFCCP’s pending rulemaking to revise its Section 503 regulations.

Bottom line: the expiration date alone doesn’t end the underlying self-ID requirement, and employers may continue using Form CC-305 after April 30th.

What It Means

The expiration date, established by OMB, does not alter contractors’ obligations to comply with OFCCP’s regulations. Instead, it limits OFCCP’s authority to mandate the use of a specific form. Contractors may continue to use Form CC-305 to satisfy the self-ID requirement, even if OFCCP’s authorization to require the form expires.

What You Should Do

Contractors should continue to comply with OFCCP’s disability self-ID regulations unless and until they are formally revised. Continuing to use Form CC-305, even if it expires on April 30, complies with OFCCP’s requirement to invite employees and applicants to voluntarily self-identify as having a disability. OFCCP has asked OMB to extend the authorization for the current form. If that extension is approved—or if OFCCP changes the form or the underlying requirement—we’ll share an update here.

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Should Contractors Keep Using OFCCP’s Disability Self-ID Form If It Expires?

Apr 27, 2026 – OFCCP’s disability self-identification form is expiring on April 30, but federal contractors may continue using the form to comply with the self-ID requirements of Section 503’s regulations.

OFCCP Updates Form CC-305 Expiration Date

May 14, 2026 – OFCCP has updated its Voluntary Self-Identification of Disability (Form CC-305) to a May 31, 2026 expiration date. Contractors may, at their discretion, update their forms or continue using the expired form until OMB formally approves an extension.

OFCCP Requests Comments on Proposed Elimination of Form CC-305

Sep 15, 2025 – OFCCP is soliciting comments on proposed revisions to an information collection request but will seek OMB approval only if a final rule is issued eliminating many longstanding disability compliance requirements.

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Mar 22, 2023 – In conjunction with the 30th anniversary of the federal Family and Medical Leave Act, we’ve updated CWC’s popular FMLA Compliance Outline, a comprehensive resource designed to assist our members in understanding the FMLA’s basic requirements.

CWC Interstate: February 2024 Update

Feb 26, 2024 – CWC's February 2024 Interstate Update reports on recent updates in paid leave and pay transparency laws, including Massachusetts' updated paid leave rates, Chicago's ordinance delay, and D.C. and NYC salary posting requirements.

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