OFCCP Compliance

OFCCP compliance means meeting the affirmative action and nondiscrimination rules enforced by the Office of Federal Contract Compliance Programs, an agency inside the U.S. Department of Labor. The rules apply to companies that hold federal contracts or subcontracts, not to every employer.

The picture changed in 2025. Executive Order 11246, which supported most OFCCP work on race and sex, was revoked. Two laws still stand: Section 503 of the Rehabilitation Act, which covers people with disabilities, and VEVRAA, which covers protected veterans.

What Changed for OFCCP in 2025?

On January 21, 2025, Executive Order 14173 revoked Executive Order 11246. Secretary's Order 03-2025 followed on January 24 and told OFCCP to stop investigative and enforcement activity under that order, according to the OFCCP website.

OFCCP also closed its pending compliance reviews. It paused Section 503 and VEVRAA work for a time, then lifted that pause. Its site now states that both laws and their regulations remain in effect.

Check that page before you change any process. The rules have moved several times in a short period, and this entry reflects the site as of October 2026.

Which Laws Does OFCCP Still Enforce?

Section 503 and VEVRAA both require contractors to avoid discrimination and to take affirmative steps to recruit and advance covered people. Which duties apply to you depends on employee count and contract value, so confirm what your own contract triggers.

OFCCP's site says the certification period for these affirmative action programs will remain closed. That is a filing question. It does not erase the underlying regulations, so ask counsel before you retire an existing affirmative action plan.

What Do Contractors Still Have to Do Under Section 503 and VEVRAA?

The regulations ask for a mix of outreach, review, and recordkeeping. The core duties below come from the Section 503 rules, and the VEVRAA rules follow a similar pattern for veterans.

• Invite applicants to self-identify as a person with a disability, once when they apply and again after an offer.
• Review hiring and promotion processes so they do not screen out qualified people, and provide reasonable accommodation.
• Document outreach and recruitment efforts and keep those records for three years.
• Compare applicants and hires each year, covered group against total, and keep that comparison for three years.

Other personnel records follow a general rule of two years, or one year for contractors with fewer than 150 employees or a contract under $150,000. The three-year items above are the exception, as set out in 41 CFR 60-741.80.

Does Anything Else Still Apply to Contractors?

Yes. Title VII, the Americans with Disabilities Act, and the other laws enforced by the EEOC apply to most employers whether or not they hold federal contracts. Many states and cities also run their own equal opportunity and pay rules.

Your contract language may carry its own terms as well. Read the clauses, since the end of Executive Order 11246 does not change what a specific contract says.

If you ran a full plan under the old order, talk to counsel before you delete data or stop collecting it. Those records can still matter in an EEOC charge or a state claim.

How Should HR Handle OFCCP Compliance Now?

Start by confirming which contracts you hold and whether Section 503 or VEVRAA duties attach to them. Then decide what you keep doing by default. Dropping a practice is easy. Rebuilding it after a rule change is not.

• Keep the self-identification invitations and store the answers apart from hiring files.
• Keep outreach logs and the annual applicant and hire comparisons.
• Review job requirements and tests for anything that screens out people with disabilities without a business reason.
• Set a calendar reminder to recheck the OFCCP page each quarter.

The goal is a process you could explain to an auditor, a lawyer, or a hiring manager in plain language.

How Does HR Cloud Fit Into OFCCP Compliance?

HR Cloud is not an OFCCP compliance tool. Its recruiting page describes custom hiring stages, applicant records that keep applications, notes, files, and status in one place, and dashboards that cover candidate sources, pipeline movement, and open roles.

The page does not describe EEO or OFCCP reporting, adverse impact analysis, or self-identification reports. Contractors need a separate process or a specialized system for those, and HR Cloud can sit alongside it as the place the applicant record lives.

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Frequently Asked Questions

Q: What does OFCCP stand for?

A: It stands for the Office of Federal Contract Compliance Programs, a U.S. Department of Labor agency that oversees obligations of federal contractors and subcontractors.

Q: Does OFCCP still enforce anything?

A: Yes. Its website says Section 503 of the Rehabilitation Act and VEVRAA, along with their regulations, remain in effect.

Q: Is Executive Order 11246 still in effect?

A: No. Executive Order 14173 revoked it on January 21, 2025, and OFCCP was told to stop enforcement activity under it.

Q: Do I still need an affirmative action plan?

A: The Section 503 and VEVRAA regulations remain in effect, and whether they require a plan depends on your employee count and contract value. Confirm with counsel.

Q: Who is covered by Section 503 and VEVRAA?

A: Federal contractors and subcontractors, with specific duties set by factors such as the number of employees and the size of the contract.

Q: How long should contractors keep hiring records?

A: Generally two years, or one year for smaller contractors. Outreach documentation and the annual applicant and hire comparisons must be kept for three years.