A newly released Government Accountability Office (GAO) report calls on the Department of Labor (DOL) to strengthen its oversight of federal contractors’ compliance with Section 503 of the Rehabilitation Act and provide more guidance to help them meet their obligations. DOL agreed with six of GAO’s eight recommendations but neither agreed nor disagreed with the other two.
GAO’s report, publicly released on Oct. 6, 2026, highlights the value of Section 503 audits as a compliance monitoring tool, even though the Office of Federal Contract Compliance Programs (OFCCP) suspended them in early 2025. OFCCP also paused contractors’ affirmative action program (AAP) certifications, which were previously submitted by contractors through OFCCP’s Contractor Portal. GAO reported that this was done despite the fact that 532 audits conducted by OFCCP between fiscal years 2017 and 2025 found violations of Section 503. Without audits, GAO said, DOL has less assurance that contractors are meeting their obligations to support employment of people with disabilities.
GAO recommended resuming both the AAP contractor certifications, as well as Section 503 audits. GAO also recommended OFCCP review how certain Section 503 complaints are handled, planning for OFCCP’s staffing needs, and providing contractors with more resources on recruitment, reasonable accommodations, outreach, and compliance practices.
In response, DOL said it has no current plans to resume any contractor certifications or audits, and it is evaluating its compliance activities following recent regulatory changes, including the elimination of disability status self-identification and AAP utilization “goals.”
What This Means for Contractors
While DOL indicated no plans to remove the pause in certifications and audits, future administrations may take note of GAO’s recommendations. Significantly, contractors still have an obligation to maintain written Section 503 AAPs and ensure affirmative action for applicants and employees with disabilities. Although DOL removed the disability self-identification invitation requirement and seven percent utilization goal from its Section 503 regulations in August 2026, other requirements remain. Contractors should review their current AAPs and practices against those requirements while monitoring OFCCP’s response to the report.
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