Federal Contractor Compliance Reset: What DOL’s Three Final Rules Change, and What They Don’t

TLG

On August 21, 2026, the Department of Labor published three final rules that reshape the federal contractor compliance framework. Some obligations are gone. Others remain and need to be maintained. A few have changed in ways that affect forms, thresholds, and records.

Here is how each rule works and what it means for your back office.

Three Rules, Three Dates

Rule Effective date
Section 503 (disability) September 21, 2026 (Part 60-30 removal: December 21, 2026)
VEVRAA (veterans) September 21, 2026
EO 11246 rescission October 26, 2026

EO 11246: The Regulations Come Off the Books

DOL rescinded its EO 11246 regulations effective October 26, 2026. This formalizes a change already in motion. EO 14173 revoked EO 11246 in January 2025, OFCCP stopped enforcing it, and contractors were told to wind down compliance by April 21, 2025.

The rescission ends the regulatory requirement for race- and sex-based affirmative action plans. Law firm summaries also report that it removes the EO 11246 pay transparency provisions.

Your general anti-discrimination obligations are not affected. Title VII and applicable state and local laws still apply, and your contracts may carry their own clauses.

Section 503: Fewer Tools, Same Core Duties

This rule makes the most substantive changes. DOL rescinded:

  • The requirement to invite applicants and employees to self-identify, including the CC-305 form
  • The related data collection requirements
  • The 7% utilization goal and the annual utilization analysis

DOL’s reasoning is that a mandated inquiry conflicts with the ADA. The ADA bars pre-offer disability inquiries and permits post-offer inquiries only under conditions that the Section 503 regulations did not include. DOL also says it is not forbidding inquiries that contractors believe are lawful. It simply no longer requires them. Talk to counsel before keeping any disability inquiry in your process.

What stays:

  • Nondiscrimination and reasonable accommodation requirements
  • Affirmative action programs for contractors with 50 or more employees and a contract of $50,000 or more
  • Outreach and recruitment, with an annual assessment of effectiveness
  • An audit and reporting system to measure the program’s effectiveness

DOL also clarified that contractors no longer have to weigh disability applicant and hire counts when assessing outreach. Other measures count, such as the accessibility of outreach and hiring materials.

The basic coverage threshold rose from $15,000 to $20,000 in contract value.

VEVRAA: Mostly Technical, With One Real Change

The VEVRAA rule removes EO 11246 cross-references and moves the administrative enforcement procedures into the VEVRAA regulations. It imposes no new obligations.

The practical change is the threshold. VEVRAA coverage now starts at $200,000, up from $150,000. The AAP requirement applies to contractors with 50 or more employees and a contract of $200,000 or more. DOL expects some contractors to drop out of coverage.

VEVRAA did not follow Section 503. Veteran self-identification and veteran affirmative action plans continue.

One Open Item: AAP Certification

OFCCP’s website says the certification period for Section 503 and VEVRAA affirmative action programs remains closed while it revises its systems. Plans still must be prepared and maintained. There is just no certification step for now.

What This Means for Your Operations

  • Onboarding and HR forms: Review and likely retire the CC-305 and related disability inquiry steps. Keep veteran self-identification.
  • Affirmative action plans: Stop race and sex plans after October 26. Keep Section 503 and VEVRAA plans where your thresholds apply.
  • Coverage review: Recheck each contract against the new $20,000 and $200,000 thresholds.
  • Compliance tracking: Training, licensing, and clearance tracking is unaffected and remains central to contract performance.
  • Records: Confirm retention requirements under your contracts and other laws before purging historical records.
  • Handbooks and policies: Review pay transparency language and anything built around the old frameworks.
  • State and local rules: Federal rescission does not remove them.

The Practical Takeaway

Treat this as a targeted review, not a teardown. Inventory every form, report, and process tied to EO 11246, Section 503, and VEVRAA. Retire only what the rules clearly eliminate. Keep what remains. Then confirm with employment counsel and document your decisions.

This article is for general information and is not legal advice.