Federal Contractor Reporting Obligations

Federal Contractor Reporting Obligations Are Changing

Summary

Federal contractors have in the past had certain reporting obligations including the filing of reports with federal agencies and the certification of compliance with affirmative action program (AAP) requirements. Under the Trump administration, some of these have obligations have changed.

• The AAP certification required by the Office of Federal Contract Compliance (OFCCP) is on hold.

• The Equal Employment Opportunity Commission (EEOC) has plans to rescind the collection of EEO-1 reports and there has been no indication there will be EEO-1 reporting this year.

• While federal contractors still have reporting obligations regarding individuals with disabilities and protected veterans, OFCCP currently has no plans for conducting reviews of whether these reporting obligations have been met.

Only one reporting obligation, the annual VETS-4212 reporting obligation, appears to be unchanged.

AAP Certification

Beginning in 2022, OFCCP required federal contractors to annually certify that they had maintained AAPs associated with the three laws the agency enforced. In 2025, the Trump administration revoked one of these laws, Executive Order 11246, and began a significant downsizing of staff and activities at OFCCP. As part of these limitations on OFCCP activities, there was no AAP certification during 2025.

In January of 2026, the OFCCP website was revised to include this statement:

 [W]hile OFCCP continues to work to revise its processes and systems to reflect changes to OFCCP's scope of mission and authority with the revocation of E.O. 11246, the Section 503 and VEVRAA affirmative action program (AAP) certification period will remain closed.

Unless there is some dramatic change by OFCCP, federal contractors will not be required to certify they are meeting their AAP obligations during 2026.

EEO-1 report

Since 1966, employers with at least 100 employees have been required to file an EEO-1 report. Federal contractors with at least 50 employees were also required to file this report. In recent years, the EEOC has provided an online portal for employers to file the report. The most recent EEO-1 reporting period began in May of 2025 when employers were required to provide data on persons employed during 2024.

EEOC should be conducting a collection of 2025 data during 2026. The agency currently has a notice on its website that states:

Updates regarding the 2025 EEO-1 Component 1 data collection will be posted to this page as they become available.

There are two factors which are affecting EEO-1 data collection during 2026.

• On May 14, 2026, EEOC sent a notice to the Office of Management and Budget (OMB) proposing to end EEO-1 and related reporting. On July 8, 2026, EEOC sent a second notice to OMB stating that the agency intends to soon publish a rule that rescinds the requirement to collect EEO-1 and related data.

• EEO-1 reporting has for many years been managed by a third-party vendor. The contract with the most recent vendor expired in December 2025, and there have been no efforts to renew this contract or find a new vendor.

Thus, it appears that EEOC has no desire to conduct an EEO-1 data collection during 2026 and has no practical way to do so even if the agency changed its position and decided to move forward with an EEO-1 data collection.

Until regulations associated with EEO-1 data collections are changed, federal contractors and other employers have reporting obligations to submit EEO-1 reports. Employers should continue to keep data that would allow them to submit EEO-1 reports until any rescission of this reporting is finalized. However, it is unlikely this data will be submitted to EEOC any time during 2026.

AAPs for Individuals with Disabilities and Protected Veterans

While there have been significant changes in the affirmative action and EEO environment in the last 18 months, federal contractors are still required to prepare AAPs for individuals with disabilities and protected veterans. These AAPs are required under Section 503 of the Rehabilitation Act (Section 503) and the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA). OFCCP’s website has the following statement:

Contractors are reminded…that Section 503 and VEVRAA, along with their implementing regulations, remain in effect and contractors should continue to otherwise comply with their obligations under the Section 503 and VEVRAA regulatory schemes.

Among the reporting obligations associated with Section 503 and VEVRAA are the following:

• Federal contractors must prepare written AAPs.

• Federal contractors must collect and review data on applicants and hires and prepare an assessment of external outreach and recruitment efforts; and,

• The Section 503 AAP must include a disability utilization of the workforce.

In July of 2025, OFCCP proposed to eliminate the data collection reporting requirements under Section 503, but there has been no final action on this proposal. VEVRAA reporting obligations were not affected by this proposal. Thus, federal contractors continue to be subject to reporting obligations that have been in place since 2013.

OFCCP has traditionally conducted compliance reviews to verify that federal contractors are meeting their obligations under the laws enforced by the agency. However, since February 2025, OFCCP has not been conducting compliance reviews. Federal contractors continue to have requirements to produce AAPs and meet other reporting obligations associated with Section 503 and VEVRAA, but it is unlikely contractors will be required to provide AAPs to OFCCP or any other agency during 2026.

VETS-4212

One of the few reporting obligations that has not changed is the requirement for federal contractors to annually file the VETS-4212 report. This report is required under VEVRAA. The report is typically filed using a portal developed by the Veterans Employment and Training Service (VETS). The portal is supposed to open in early August, and reporting must be completed by September 30.