OFCCP has published proposed modifications to the VEVRAA and Section 503 regulations which govern federal contractor affirmative action obligations for veterans and individuals with disabilities.

The proposed changes to the veterans’ regulations are largely procedural – removing references to Executive Order 11246 and its implementing regulations – resulting in the veterans’ regulations being wholly self-contained and not reliant on incorporation of the inoperable 11246 regulations. As a note, the Agency has also simultaneously proposed to formally rescind the Executive Order 11246 regulations in an effort to address any confusion as to their status following President Trump’s revocation of Executive Order 11246 in January 2025.

Conversely, while including the same Executive Order 11246 modifications, OFCCP proposes additional modifications to the Section 503 regulations which are more material – proposing to eliminate self-identification data collection and utilization analyses for individuals with disabilities. The proposal does not suggest removing contractors’ obligations to assess the effectiveness of their outreach efforts, however.

To be clear, the obligation to prepare affirmative action plans under both VEVRAA and Section 503 remain intact under OFCCP’s proposals.

The proposed rules are now open for a 60-day public comment period.

We continue to digest the changes and will be back with more insights as they develop.

Tags: Equal Employment Opportunity Commission, Executive Order 11246 implementing regulations, Executive Order 14173, individuals with disabilities, OFCCP, Office of Federal Contract Compliance Programs, Section 503, veterans, VEVRAA
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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.

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