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Quick Hits
- On September 4, 2025, OFCCP published in the Federal Register a fifteen-day extension to the comment period for Section 503 and VEVRRA regulations and the rescission of the regulations for EO 11246.
- With the fifteen-day extension, comments to the proposed regulatory changes to Section 503, VEVRAA, and EO 11246 are now due on or before September 17, 2025.
After the Labor Day holiday weekend, OFCCP issued notices extending the comment periods for the notice of proposed rulemakings (NPRM) for Section 503 and VEVRAA to September 17, 2025. OFCCP also issued an extension to the comment period for the proposal to rescind the regulations that implemented EO 11246.
The proposal for Section 503 seeks to rescind the requirements for contractors to invite applicants and employees to self-identify their disability status and to analyze progress toward the 7 percent utilization goal for individuals with disabilities. More than 150 comments have been submitted since the July 1, 2025, proposal was published. The proposal for VEVRAA seeks to remove references to Executive Order 11246 and add administrative enforcement proceeding provisions directly to the VEVRAA regulations in 41 CFR part 60-300.
Next Steps
Stakeholders are encouraged to submit their comments by September 17, 2025, as no further extensions will be granted.
OFCCP’s September 4, 2025, extension of the comment period does not affect the separate solicitation for comments regarding specific questions related to a proposal for modification to the Office of Management and Budget’s disability data collection form, as part of its broader proposed regulatory update. Those comments are still due by October 24, 2025, meaning that the government will likely be in a new fiscal year before OFCCP finalizes its various Section 503 updates.
Existing compliance requirements including preparation of affirmative action programs (AAPs) and other technical requirements are unchanged in the interim, as the current Section 503 and VEVRAA regulations remain in effect until OFCCP finalizes any proposals.
Ogletree Deakins’ Government Contracting and Reporting Practice Group and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Diversity, Equity, and Inclusion Compliance, Government Contracting and Reporting, Government Contractors, and Workforce Analytics and Compliance blogs as additional information becomes available.
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