- with readers working within the Business & Consumer Services and Consumer Industries industries
On July 16, 2026, the Office of Management and Budget (OMB) has approved the continued use of Form CC-305 (Voluntary Self-Identification of Disability), reaffirming that covered federal contractors remain subject to the disability self-identification requirements under Section 503 of the Rehabilitation Act. The approved form is available on the U.S. Department of Labor’s website. OFCCP CC-305 Self-Identification Forms
What This Means for Federal Contractors
Although Executive Order 11246 has been revoked, the Section 503 disability requirements remain in effect. Federal contractors covered by Section 503 must continue to:
- Invite applicants to voluntarily self-identify as individuals with disabilities at the appropriate stages of the hiring process.
- Invite newly hired employees to voluntarily self-identify.
- Survey all employees at least once every five years and remind employees at least once during the intervening years that they may voluntarily update their disability status.
- Maintain disability self-identification data confidentially and separate from personnel files.
- Use the OMB-approved Form CC-305 without substantive modification, except as permitted by OFCCP guidance. (U.S. Department of Labor)
Why This Is Important
Some employers mistakenly assumed that recent changes affecting Executive Order 11246 also eliminated disability-related compliance obligations. They did not.
Section 503 remains in force, and federal contractors are still required to collect voluntary disability self-identification data and evaluate their employment practices for individuals with disabilities. These requirements continue to be an important component of federal contractor compliance programs. (U.S. Department of Labor)
Recommended Next Steps
- Verify that the current OMB-approved Form CC-305 is being used in applicant tracking and onboarding systems.
- Confirm that employee disability surveys and reminder schedules comply with Section 503 requirements.
- Review policies, procedures, and recordkeeping practices for disability compliance.
- Evaluate workforce data to identify potential barriers to equal employment opportunity for individuals with disabilities.
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.
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