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ARTICLE · 14 SEPTEMBER 2026

OFCCP Eliminates Self-Identification Requirement And Other Disability-Related Affirmative Action Mandates Under Section 503

The U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) has finalized a rule which will significantly modify the implementing regulations to Section 503 of the Rehabilitation Act.

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The U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) has finalized a rule which will significantly modify the implementing regulations to Section 503 of the Rehabilitation Act. The revised regulations, which streamline federal contractors affirmative action obligations under Section 503, will go into effect on Sept. 21, 2026.

The most significant change is the rescission of the requirement for federal contractors to invite applicants and employees to voluntarily self-identify as individuals with disabilities. Federal contractors have been required to use OFCCP’s self-identification form, Form CC-305, to meet this requirement. The new regulations retire OMB Form CC-305. To be clear, OFCCP has not decided to do away with their mandated self-identification form and left employers to develop their own form. The new regulations have ended the voluntary self-identification practices under Section 503 altogether. The DOL takes the position that the

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