OFCCP Updates Jurisdictional Thresholds
- Ellen Shong & Associates
- Nov 26, 2025
- 2 min read
On November 25, 2025, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) announced updates to the jurisdictional thresholds for the two laws the agency enforces. These laws are Section 503 of the Rehabilitation Act of 1973 (Section 503) and the Vietnam Era Veterans Readjustment Assistance Act of 1974 (VEVRAA). Section 503 requires federal contractors to make efforts to employ individuals with disabilities, while VEVRAA requires federal contractors to make efforts to employ certain classes of veterans.
The announcement from OFCCP stated that the jurisdictional thresholds regarding Section 503 and VEVRAA were updated on October 1, 2025. The monetary threshold regarding basic coverage under Section 503 increased from $15,000 to $20,000, while the monetary threshold for any type of coverage under VEVRAA increased from $150,000 to $200,000. These updates to jurisdictional thresholds are the result of inflationary adjustments authorized by the Federal Acquisition Regulatory Council.
OFCCP has two types of coverage for federal contractors:
Basic coverage, where federal contractors are required to prevent discrimination and take certain specific steps to employ members of the relevant protected class.
AAP coverage, where federal contractors are required to prepare affirmative action plans and take more extensive action to employ members of the relevant protected class.
Basic coverage under Section 503 and VEVRAA does not depend on the number of persons a federal contractor employs. For there to be AAP coverage, a federal contractor must have at least 50 employees. The dollar threshold associated with basic coverage under Section 503 is $20,000, while the threshold for AAP coverage is $50,000. The dollar threshold associated with both basic and AAP coverage under VEVRAA is $200,000. OFCCP has an infographic regarding its jurisdictional thresholds.
The formal regulations associated with Section 503 and VEVRAA show that the basic coverage threshold for Section 503 is $10,000, and the threshold for coverage under VEVRAA is $100,000. These monetary thresholds changed to $15,000 and $150,000 in 2015 because of the inflationary adjustments noted above. The changes found in OFCCP's recent announcement are the first increases since 2015.
OFCCP is currently considering various changes to regulations associated with Section 503 and VEVRAA. There have been many changes at OFCCP during 2025, and budget documents from the Trump administration have proposed eliminating OFCCP. Regardless of what happens to OFCCP, federal contractors that meet the relevant jurisdictional thresholds will continue to be required to comply with Section 503 and VEVRAA.
