Changes to Section 503 Disability Affirmative Action Requirements
Beth Kerstein
The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has finalized significant changes to its regulations under Section 503 of the Rehabilitation Act, eliminating several longstanding disability-related affirmative action requirements for federal contractors and subcontractors.
The final rule is scheduled for publication in the Federal Register on August 21, 2026.
What’s Changing?
Under the new Section 503 regulations, federal contractors will no longer be required to:
- Invite applicants and employees to self-identify as individuals with disabilities.
- Collect and maintain disability self-identification data for affirmative action purposes.
- Measure their workforce against the 7% utilization goal for individuals with disabilities.
What Remains Required?
While several data collection and utilization requirements have been eliminated, Section 503 itself remains in effect. Covered federal contractors and subcontractors must continue to:
- Prepare a written Affirmative Action Plan (AAP) annually.
- Take affirmative action to employ and advance qualified individuals with disabilities.
- Comply with Section 503’s nondiscrimination requirements.
- Assess the effectiveness of outreach and recruitment efforts focused on individuals with disabilities.
Contractors and subcontractors will no longer be required to collect or evaluate disability data as part of that outreach assessment.
What Should Employers Do Now?
This change represents a significant shift in the affirmative action compliance requirements for federal contractors and subcontractors. Employers should review their current AAPs, self-identification processes, forms, policies, and data collection practices to determine what changes may be appropriate once the final rule takes effect.
MRA will continue to monitor the implementation of this rule and provide additional guidance as more information becomes available.
Please note that this compliance update voids the DOL's previous update regarding the extended expiration date of the Voluntary Self-Identification of Disability Form (CC-305).
If you have further questions or need assistance, contact us for guidance and support. MRA members can reach out to our 24/7 HR Hotline.
