In conjunction with the recent proposed rule changes to the Section 503 of the Rehabilitation Act of 1973 (Section 503) and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA) regulations, the Department of Labor (DOL) announced OFCCP has the authority to resume its enforcement activities related to veterans and individuals with disabilities.

On July 2, 2025, Secretary of Labor Lori Chavez-DeRemer issued Secretary’s Order 08-2025, officially lifting the prior temporary pause on enforcement put in place in January 2025 by the then Acting Secretary of Labor. Prompted almost immediately by EO 14173, the prior order, Order 03-2025, directed OFCCP to halt all activities under EO 11246. Order 03-2025 also placed OFCCP’s activities related to Section 503 and VEVRAA in abeyance. The DOL asserted this temporary pause was necessary to unwind EO 11246 programs and separate them from OFCCP’s Section 503 and VEVRAA compliance structure, ensuring that the “OFCCP did not undertake any activity for which it was not authorized.” 

With the abeyance lifted, DOL announced OFCCP can resume work on VEVRRA and Section 503 complaints immediately.

However, with respect to compliance reviews, the notice explained

OFCCP will be exercising its discretion to administratively close all pending compliance reviews and will take no further action related to the scheduling list released in November 2024.  Impacted contractors will promptly receive formal notification of the administrative closure of the pending compliance review. 

Additionally, the notices confirm the Section 503 and VEVRAA affirmative action program (AAP) certification process remains closed at this time and reiterates the Veterans Affairs Health Benefits Program (VAHBP) enforcement moratorium has been extended through May 7, 2027. Despite this, Secretary Chavez-DeRemer’s order reminds contractors that they must continue to meet their obligations under Section 503 and VEVRAA regulations.

Importantly, Secretary’s Order 08-2025 does not rescind the prior DOL order in its entirety. Secretary’s Order 03-2025 provisions related to EO 11246 remain in effect. As outlined in the earlier order, OFCCP must “cease and desist” the Agency’s investigative and enforcement activities under the EO 11246.

If you have questions about OFCCP’s resumed activities and how they could affect your organization, contact a Jackson Lewis attorney to discuss your specific situation and compliance obligations.

Tags: individuals with disabilities, OFCCP, Office of Federal Contract Compliance Programs, Section 503, Section 503 Rehabilitation Act of 1973; Regulations for Disabled Individuals, veterans, VEVRAA, Vietnam Era Veterans Readjustment Assistance Act
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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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