OFCCP Resumes Enforcement for Disability and Veteran Protections
Debbie Rich
After a brief pause in 2025 following the revocation of Executive Order 11246, the Office of Federal Contract Compliance Programs (OFCCP) has resumed investigating certain employment discrimination complaints. As of late 2025, the agency is once again enforcing protections for individuals with disabilities under Section 503 of the Rehabilitation Act of 1973 (Section 503) and for protected veterans under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).
Because the OFCCP no longer has authority to handle complaints related to race, sex, religion, or similar categories, it updated its complaint forms to focus only on disability and veteran status in July 2025. While the forms have changed, the way complaints are submitted has largely stayed the same. The updated forms include the Pre-Complaint Inquiry Form (Form CC-390), which helps determine the OFCCP’s jurisdiction before a formal complaint is filed, and the Formal Complaint Form (Form CC-4), which is used to submit an official discrimination complaint.
Federal contractors and subcontractors must therefore continue to comply fully with their obligations under Section 503 and VEVRAA. These responsibilities generally include:
- soliciting voluntary self-identification of disability and protected veteran status,
- maintaining annual affirmative action plans for individuals with disabilities and protected veterans,
- listing job openings with state and local employment service delivery systems, and
- ensuring nondiscrimination in all employment practices related to disability and veteran status.
As the agency charged with enforcing these statutes, the OFCCP is required to promptly investigate complaints alleging violations of these regulations. Additionally, with new leadership and potentially significant funding on the horizon, federal contractors should expect more activity from the agency in the near future.
If you need assistance with your Section 503 and VEVRAA obligations, MRA can help. Contact us to learn more about our Affirmative Action Compliance Services.
