As of October 1, 2025, the jurisdictional thresholds for two key regulations impacting federal contractors—the Rehabilitation Act (Section 503) and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA)—have increased. These changes stem from an inflationary adjustment statute that authorizes the Federal Acquisition Regulatory Council to review and update acquisition-related thresholds in statutes governing federal procurement.

What Changed?

  • Section 503 of the Rehabilitation Act
    • Coverage threshold increased from $15,000 to $20,000.
  • VEVRAA
    • Coverage threshold increased from $150,000 to $200,000.

Impact on Affirmative Action Program (AAP) Requirements

  • For VEVRAA, AAP requirements now apply to contractors and subcontractors with:
    • At least 50 employees, and
    • A single contract of $200,000 or more.
  • For Section 503, AAP requirements continue to apply to contractors and subcontractors with:
    • At least 50 employees, and
    • A single contract of $50,000 or more.

To help employers and stakeholders navigate these changes, the Office of Federal Contract Compliance Programs (OFCCP) has:

We are still awaiting updates from the agency on the proposed changes to the Veterans and Disability implementing regulations.

For any questions regarding these or other federal contractor obligations please contact the Jackson Lewis attorney with whom you work.

Tags: individuals with disabilities, OFCCP, OFCCP jurisdictional thresholds, Office of Federal Contract Compliance Programs, Section 503, Section 503 of the Rehabilitation Act of 1973, 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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