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Quick Hits
- The Office of Management and Budget (OMB), through the Office of Information and Regulatory Affairs (OIRA), has renewed Form CC-305, which invites applicants and employees of covered contractors to identify their disability status through July 31, 2029.
- The renewal means covered contractors subject to Section 503 self-identification requirements should continue using the OMB-approved form bearing the new expiration date.
On July 16, 2026, OMB approved Form CC-305 (Voluntary Self-Identification of Disability) and extended it for use through July 31, 2029, without substantive changes to the previous version. The renewal comes after the approval of the prior form expired on April 30, 2026.
Disability Self-Identification
Section 503 of the Rehabilitation Act prohibits covered contractors and subcontractors from discriminating against job applicants and employees with disabilities and requires those contractors and subcontractors to take affirmative action to employ and advance in employment qualified individuals with disabilities. In 2014, the U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) introduced Form CC-305, which is used to invite job applicants and current employees to voluntarily and confidentially disclose their disability status. OMB must approve and renew the form every three years. The form was last updated in 2023.
Proposed Rescission
On July 1, 2025, OFCCP published a proposed rule to revise regulations implementing Section 503 of the Rehabilitation Act to align with Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” and Executive Order 14219, “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative.”
The proposed rule calls for rescission of the requirement that covered contractors (1) invite applicants and employees to self-identify their disability status under 41 C.F.R. § 60-741.42 and (2) analyze progress toward the 7 percent utilization goal for individuals with disabilities under 41 C.F.R. § 60-741.45. OFCCP extended the comment period on the proposed rule to September 17, 2025, and more than 650 comments were submitted. A final rule, however, has not been approved by the administration or published.
In August 2025, OFCCP followed up its proposal with a separate request for comment, titled, “Proposed Revision of Information Collection Request,” soliciting comments on its information collection, including whether OFCCP must collect information to carry out its functions.
Renewal of Form CC-305
The renewal of Form CC-305 for another three years, without substantive amendments, may indicate that the DOL has considered public comments opposing rescission of the data collection requirements and confirmed that Section 503 of the Rehabilitation Act remains in full force and effect. However, contractors may want to note that the DOL/OFCCP could move forward with the rescission proposal at some point in the future.
Next Steps
Covered federal contractors must continue to invite applicants and employees to self-identify their disability status and should begin using the OMB-approved Form CC-305. OFCCP has published a copy of the form with the new expiration date for contractors to use, which can be downloaded in English and several other languages here.
Ogletree Deakins’ Diversity, Equity, and Inclusion Compliance Practice Group, Government Contracting and Compliance 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 Compliance, and Workforce Analytics and Compliance blogs as additional information becomes available.
This article and more information on how the Trump administration’s actions impact employers can be found on Ogletree Deakins’ Administration Resource Hub.
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