OFCCP Form Regarding Disability Status Expires April 2026
- 21 hours ago
- 3 min read
The form that the Office of Federal Contract Compliance Programs (OFCCP) requires federal contractors and subcontractors to use to gather information on disability status expires in April 2026. Federal contractors and subcontractors are required to provide the form to applicants and employees who may be individuals with disabilities so that they can self-identify their disability status.. The Office of Management and Budget (OMB) has only approved the use of the form until April 30, 2026.
Offer to Self-Identify
There are regulations associated with Section 503 of the Rehabilitation Act (Section 503) that apply to federal contractors and subcontractors (“contractors”) with a single contract or subcontract of $50,000 or more and at least 50 employees. Included among these regulations are requirements that contractors offer an opportunity to self-identify disability status to:
Applicants during the pre-offer stage of the employment process
Applicants during the post-offer stage of the employment process
Employees at least once every five years
The Section 503 regulations state that contractors “shall…[use] the language and manner prescribed by the Director [of OFCCP] and published on the OFCCP Web site” for these purposes. Contractors are not allowed to develop their own self-identification forms.
Self-Identification Form Requires OMB Approval
The OFCCP self-identification form must be approved by OMB before OFCCP can require the use of the form by contractors. The current form, referred to as form CC-305, was last approved by the OMB in 2023. In order for OFCCP to require contractors to continue using form CC-305 after April 2026, OFCCP must receive approval from OMB. Renewing government forms has been a routine request made by OFCCP and other federal agencies. However, as of the publication date of this blog, OFCCP has not taken any visible steps to either request re-approval of the existing form or submit a revised form for approval.
It is unclear why the OFCCP has not taken the necessary steps to have form CC-305 approved. However, there are two possible reasons for this delay.
In 2025, OFCCP proposed changes to the Section 503 regulations which would eliminate the requirement to provide a form to applicants or employees for use in self-identifying disability status. While these changes have not moved forward, OFCCP may be expecting that its regulations will ultimately eliminate the requirement to provide a self-identification form.
With the uncertainty of OFCCP’s continuing existence, OFCCP may have decided to suspend action on renewal of forms and changes to regulations until final decisions have been made about the agency's future.
Actions to Take
Federal contractors and subcontractors have at least two options when form CC-305 expires in April 2026. They can:
Continue to use form CC-305 past its April 30 expiration date. This would allow contractors to satisfy the requirement to collect information on disability status from applicants and employees. In 2023, there was a similar delay in OFCCP’s submission of form CC-305 for re-approval. Contractors continued to use the older version of the form without consequence.
Suspend collection of information on disability status until OMB re-approves form CC-305 or approves a successor to this form. Contractors are not obligated to use an outdated and unauthorized form, and OFCCP's regulations specifically state that contractors must use an OFCCP mandated form to collect information on disability status.
Form CC-305 has been integrated into many human resource information systems and applicant tracking systems used by contractors. Contractors should discuss the use of CC-305 with their vendors after making on a decision on whether to continue using the form.