Following President Trump's revocation of Executive Order 11246 in January 2025, federal contractors with compliance reviews in progress received notice that the Executive Order 11246 component of the review was being closed, but that Section 503 of the Rehabilitation Act of 1973 (protecting the disabled) and VEVRAA (protecting certain veterans) components were only being held in abeyance until further notice.
Further notice has now been provided. On July 2, 2025, OFCCP announced that it will "administratively close all pending compliance reviews and will take no further action related to the scheduling list released in November 2024." Presumably, OFCCP will also take no further action with regard to audit targets that had been identified on scheduling lists prior to November 2024. OFCCP states that contractors will be promptly receiving formal notice of the closures.
As part of this communication, OFCCP also reminds contractors that "Section 503 and VEVRAA, along with their implementing regulations, remain in effect and contractors should continue to otherwise comply with their obligations under the Section 503 and VEVRAA regulatory schemes." At the same time, OFCCP confirms that, at least for now, contractors are not being required to certify compliance with these requirements through the Contractor Portal.
Following the revocation of Executive Order 11246, OFCCP also ceased its processing of pending and new complaints filed under Section 503 and VEVRAA. According to OFCCP's announcement, "any Section 503 and VEVRAA complaints held during the abeyance will immediately resume being processed as appropriate and affected parties will be promptly notified of this development." OFCCP will also now begin normal processing of new Section 503 and VEVRAA complaints that were filed during the abeyance.
Finally, OFCCP announced a renewal through May 7, 2027, of its exemption of Veterans Affairs Health Benefits Program (VAHBP) providers from the enforcement of affirmative obligations under Section 503 and VEVRAA or from being neutrally scheduled for Section 503 and VEVRAA compliance evaluations. OFCCP notes that this moratorium does not relieve VAHBP providers of their nondiscrimination obligations or of being subject to discrimination complaint investigations under the laws enforced by OFCCP.
For any federal contractors that were questioning whether they need to continue to comply with Section 503, VEVRAA, and their implementing rules, the OFCCP has now provided a definitive answer: Yes, compliance is still required.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
