The Office of Federal Contract Compliance Programs (OFCCP) issued a last-minute 15-day extension for submitting comments on its proposed elimination of longstanding disability compliance requirements — including self-identification, utilization analyses, and applicant tracking. The three pending Notices of Proposed Rulemaking (NPRMs) pertain to the rescission of Executive Order 11246 and revisions to the nondiscrimination and affirmative action requirements under Section 503 of the Rehabilitation Act (Section 503) and Section 4212 of the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA).

OFCCP has extended the original September 2 deadline to September 15, 2025. The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, will submit comments on all three proposals.

While the VEVRAA NPRM is largely administrative — and aligns with a corresponding proposal for rescinding Executive Order 11246 regulations — OFCCP’s proposed Section 503 changes are significant. OFCCP proposes to remove: (1) any requirement to solicit disability status from applicants or employees; (2) the need to conduct a disability utilization analysis; and (3) tracking of the disability applicant and hire metrics used to assess Section 503 outreach.

CWC will feature OFCCP’s proposals at its upcoming Workplace Compliance Conference. CWC members can read more here.