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OFCCP Resumes Enforcement and Proposes Major Changes to Section 503

  • Ellen Shong & Associates
  • Jul 9
  • 2 min read

Updated: Aug 13

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On July 2, 2025, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) announced a significant development: enforcement activity under Section 503 and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) will resume. The announcement follows Order 08-2025, issued by Labor Secretary Lori Chavez-DeRemer, officially lifting the abeyance that had paused many OFCCP activities earlier this year.


Here’s what federal contractors need to know:


Enforcement Resumes, Audits Closed

According to the OFCCP’s bulletin:

  • New and previously paused complaints under Section 503 and VEVRAA will now be processed.

  • All pending compliance reviews held since January 2025 will be administratively closed.

  • No new compliance reviews will be scheduled from the November 2024 scheduling list or any prior lists.

  • The AAP certification portal will remain closed for now.



Proposed Regulatory Changes to Section 503 and More

Just one day prior, on July 1, 2025, OFCCP proposed substantial changes to Section 503, which governs affirmative action for individuals with disabilities. Additional changes were also proposed to VEVRAA and regulations implementing Executive Order 11246.

These changes are currently open for public comment through September 2, 2025 and could be revised further before finalization.


Key Proposed Changes: Section 503:

  • Elimination of the requirement to solicit disability status from applicants and employees.

  • Removal of the “44k” summary data analysis for applicants and hires with disabilities.

  • Rescission of the 7% disability utilization goal and the related annual analysis.


Proposed Changes: VEVRAA & EO 11246:

  • Minor updates to VEVRAA language (e.g., removing EO 11246 references).

  • Rescinding of EO 11246 implementing regulations (41 C.F.R § 60-1, 60-2, 60-3, 60-20, 60-40 and 60-50), which were already nullified by Executive Order 14173 in January 2025.


Important: These are not yet final. Contractors must continue to comply with current regulations until official updates are published and take effect, likely not until late 2025 or early 2026.


ESA is continuing to monitor these developments closely. Stay tuned for updates and actionable guidance as things evolve.

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