The White House Office of Management and Budget has formally rescinded its approval of OFCCP’s disability self-ID form. Rescission of Form CC-305 was expected following DOL’s recent rulemaking eliminating Section 503’s self-identification and data analysis requirements.
OMB has updated its previous approval of the Labor Department’s written affirmative action program requirements arising under Section 503 of the Rehabilitation Act, formally removing the Voluntary Self-Identification of Disability Form (Form CC-305). All other Section 503 requirements remain intact and approved through July 2029.
Before September 21, 2026, federal contractors were required to use Form CC-305 to invite applicants and employees to voluntarily report their disability status and perform specified analytics using their responses.
Moving forward, the Americans with Disabilities Act and the Equal Employment Opportunity Commission’s implementing regulations will govern any disability inquiries. While the ADA expressly prohibits pre-offer disability solicitations, the EEOC’s implementing regulations permit post-offer, pre-employment inquiries provided that all employees are subjected to the same inquiry, regardless of disability.
Click here to read more from the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association. Employers can use CWC’s Sample Voluntary Self-Identification of Disability Form during the post-offer, pre-employment window.