Throughout 2025, federal contractor requirements have undergone numerous changes, often leading to uncertainty. Although federal requirements relating to sex and race-based affirmative action plans (AAPs) for federal contractors have ended, compliance requirements under Section 503 of the Rehabilitation Act of 1973, as amended (503)—for individuals with disabilities, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended (VEVRAA)—for veterans, have not.
Effective October 1, 2025, under a final rule issued by the Federal Acquisition Regulatory Council (Office of Federal Procurement Policy (OFPP), Office of Management and Budget (OMB); Department of Defense (DoD); General Services Administration (GSA); and National Aeronautics and Space Administration (NASA)), jurisdictional thresholds used to determine which organizations must comply with 503 and VEVRAA were updated for inflation. The rule amends the Federal Acquisition Regulation (FAR) to “further implement a statute that requires an adjustment every five years of statutory acquisition-related thresholds for inflation.”
- Section 503: Basic coverage threshold increased from $15,000 to $20,000. AAPs are still required for contractors with 50 or more employees, and a single contract of $50,000 or more.
- VEVRAA: Coverage threshold increased from $150,000 to $200,000. AAPs are required for contractors with 50 or more employees and a single contract of $200,000 or more.
Action Required
Review your organization’s federal contracts and subcontracts to determine if current and new contracts meet the new thresholds and ensure AAPs are maintained where required.
For more details, we encourage you to review the OFCCP’s announcement and the “Federal Acquisition Regulation: Inflation Adjustment of Acquisition-Related Thresholds” rule published in the Federal Register.
If you need assistance with your AAP, we can help. Contact us.