OFCCP Request for Comments on VEVRAA Requirements

OFCCP Requests Comments on VEVRAA Requirements

On January 7, 2026, the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) published a request for comments on recordkeeping and reporting requirements regarding VEVRAA. The Vietnam Era Veterans Readjustment Assistance Act (VEVRAA) is one of the two laws enforced by OFCCP. Interested parties have until March 9, 2026 to provide comments to OFCCP.

VEVRAA requires that federal contractors and subcontractors prevent discrimination against certain classes of veterans. VEVRAA also requires these employers to make efforts to find and employ veterans protected under the law. Federal contractors and subcontractors who meet certain monetary and employee thresholds must prepare affirmative action programs that meet regulations associated with VEVRAA.

OFCCP is seeking approval from the Office of Management and Budget (OMB) to continue recordkeeping and reporting currently required under VEVRAA. The agency published a supporting statement that discussed these requirements. This includes the following requirements:

• Extend an offer to applicants to self-identify protected veteran status at the pre-offer and post-offer stages of the employment process

• Maintain self-identification forms provided by applicants and employees

• Prepare and annually update the employer's affirmative action program

• Review outreach and recruitment efforts to find protected veterans

• Review the employer's audit and reporting systems

• Collect and analyze data on applicants and hires

• Develop a hiring benchmark for protected veterans

• Contact the relevant state Employment Service Delivery System when openings occur in order to find candidates who are protected veterans

OFCCP's request to continue requirements to collect and report on information associated with VEVRAA does not represent a change from the agency's previous requirements. OMB has reauthorized these requirements on multiple occasions since they were first approved in 2014. OFCCP's current authority to ensure federal contractors and subcontractors meet the requirements noted above expires on April 30, 2026.

It is not clear what will happen to OFCCP's request to reauthorize VEVRAA requirements. The agency underwent a dramatic reduction in staff in 2025, and there were no compliance reviews conducted by the agency for much of 2025. As we have previously reported, Trump administration budget proposals for federal fiscal year 2026 state that OFCCP will be shuttered and that its responsibilities will be shifted to other agencies. However, the agency has published several formal requests for comments during 2025 and 2026. This includes a recent request to OMB to modify the forms used by persons making complaints to OFCCP about allegedly discriminatory conduct by federal contractors and subcontractors. These actions suggest leaders at OFCCP and the Department of Labor expect OFCCP to continue in some capacity.