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On August 21, 2026, the U.S. Department of Labor’s (DOL) Office of the Federal Contract Compliance Programs (OFCCP) published a Final Rule on Section 503 of the Rehabilitation Act. The Final Rule goes into effect on September 21 and eliminates several established disability-related requirements instrumental to federal contractors and subcontractors’ compliance programs. Most importantly, covered contractors no longer need to collect their employees’ disability-related self-identification data or measure their affirmative action obligations against the national 7 percent disability utilization goal.
Background
The second Trump Administration has systematically rolled back affirmative action requirements for federal contractors and subcontractors. On January 21, 2025, President Trump revoked Executive Order 11246, eliminating affirmative action obligations related to their employees’ race, color, religion, sex, sexual orientation, gender identity or natural origin. As a result, federal contractors no longer need to maintain affirmative action programs for women and minorities or comply with requirements related to placement goals, availability analyses, annual plan development and recordkeeping.
Notably, President Trump’s revocation of Executive Order 11246 did not impact affirmative action obligations relating to individuals with disabilities under Section 503 of the Rehabilitation Act. The Final Rule changes this.
What’s Changing
The Final Rule removes three major compliance requirements for federal contractors and subcontractors covered by Section 503. First, it eliminates Form CC-305, meaning contractors don’t have to invite employees or applicants to self-identify as individuals with disabilities. This includes self-identification during employment, as well as pre-offer and post-offer.
Second, the Final Rule eliminates the national 7 percent utilization goal for individuals with disabilities. Prior to the Final Rule, contractors were expected to evaluate whether employees with disabilities comprise 7 percent of each job group within their workforce and, if not, implement a plan to increase the number of individuals with disabilities employed by the contractor.
Third, the Final Rule eliminates the need for contractors to collect, analyze or store disability demographic data for employees and applicants.
What’s Not Changing
The Final Rule does not eliminate all rules implementing Section 503 of the Rehabilitation Act. Covered contractors are still prohibited from discriminating against individuals with disabilities and must continue to offer reasonable accommodations and maintain a tailored affirmative action program.
Next Steps
Federal contractors and subcontractors should ensure compliance with the Final Rule by evaluating their anti-discrimination procedures and policies, especially those related to their application and onboarding systems. Importantly, covered contractors should stop collecting self-identification data for individuals with disabilities and adjust their affirmative action plans to reflect these new requirements.
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