OFCCP Ends Contractor Disability Self-ID, 7% Goal
A new final rule effective Sept. 21, 2026, removes the long-standing requirement for federal contractors to use Form CC-305 and conduct a 7% utilization analysis, though core nondiscrimination obligations remain.
The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has issued a final rule that removes long-standing disability affirmative action requirements for federal contractors. Effective September 21, 2026, the rule eliminates the 7% disability utilization goal, the associated annual utilization analysis, and the mandatory use of Form CC-305 for inviting applicants and employees to self-identify as having a disability.
This change overhauls a compliance framework that has been in place for more than a decade, easing certain specific data-collection and analytical burdens. However, the rule does not alter contractors' core nondiscrimination duties under Section 503 of the Rehabilitation Act. Contractors must still take affirmative action to employ and advance qualified individuals with disabilities and maintain written affirmative action programs where required.
Counsel should advise federal contractor clients to continue following the existing requirements until the rule's effective date. In the interim, companies should prepare by reviewing and updating their applicant tracking, onboarding, and affirmative action plan procedures and coordinating with any third-party compliance vendors.