Comment Period for Section 503 and VEVRAA Extended by OFCCP

If you’re a federal contractor, 2025 has probably felt like a never-ending compliance plot twist.
Just when you thought you had the new proposed rules for disability and veteran affirmative action
under control, the Office of Federal Contract Compliance Programs (OFCCP) dropped another update:
the comment period for Section 503 and VEVRAA has been officially extended.

On September 4, 2025, OFCCP published a notice in the Federal Register giving stakeholders an
extra 15 days to weigh in on proposed rulemakings affecting Section 503 of the Rehabilitation Act
and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), along with the proposed
rescission of the regulations implementing Executive Order 11246. With this extension, comments
are now due on or before September 17, 2025, instead of early September.

That extra time may not sound like much, but in the world of regulatory comments, 15 days can
mean the difference between a rushed, boilerplate submission and a thoughtful, strategic response
that actually influences the final rules. Let’s unpack what’s going on, what’s at stake, and how
to use this extension wiselywithout needing a law degree or three pots of coffee.

Quick Refresher: What Are Section 503 and VEVRAA?

Before getting into the comment period extension, it helps to remember why these regulations
matter so much to federal contractors.

Section 503 of the Rehabilitation Act

Section 503 prohibits federal contractors and subcontractors from discriminating against
qualified individuals with disabilities and requires affirmative action to recruit, hire,
promote, and retain them. Contractors with at least 50 employees and a single federal contract
of $50,000 or more must maintain a written affirmative action program (AAP) for individuals
with disabilities.

Under the current rules, contractors must:

• Invite applicants and employees to voluntarily self-identify as individuals with disabilities.
• Track progress toward a 7% utilization goal for individuals with disabilities across job groups.
• Maintain detailed records, outreach efforts, and internal audit processes.

VEVRAA: Protecting Veterans in the Federal Contractor Workforce

VEVRAA extends similar protections and affirmative action obligations to certain categories of
protected veterans. Contractors with at least 50 employees and a federal contract or subcontract
meeting jurisdictional thresholds must develop and maintain written AAPs for protected veterans.

Key requirements include:

• Inviting applicants and employees to voluntarily self-identify their veteran status.
• Tracking progress against an annual veteran hiring benchmark (currently around 5.1% companywide).
• Maintaining robust outreach, job listing, and recordkeeping practices.

As of late 2025, OFCCP and DOL have also increased certain jurisdictional thresholdssuch as
raising the basic coverage threshold for Section 503 contracts and increasing the VEVRAA coverage
threshold to $200,000changing which contractors are covered.

What Exactly Did OFCCP Do with the Comment Period?

On July 1, 2025, OFCCP released multiple Notices of Proposed Rulemaking (NPRMs) to revise
regulations implementing Section 503 and VEVRAA and to rescind the regulations under EO 11246.
The initial comment period was set at 60 days, with comments due in early September 2025.

After a wave of stakeholder attentionand more than 150 public comments on the Section 503
proposal alonethe agency issued a 15-day extension. Now:

• New deadline for Section 503 and VEVRAA NPRMs: September 17, 2025.
• New deadline for comments on the EO 11246 rescission proposal: Also September 17, 2025.

Importantly, OFCCP clarified that this extension does not affect a separate, later
deadline related to the disability self-identification form. Comments on the Office of
Management and Budget’s disability data collection form modifications are still due October 24,
2025.

In plain language: You now have a short but meaningful window to refine your comments on the big
rule changes, while another comment opportunity on disability data is still waiting down the
road.

What’s on the Table? Key Proposed Changes

1. Section 503: Big Shifts Around Disability Self-ID and Utilization Goals

One of the most controversial parts of the July 1 Section 503 proposal is the plan to eliminate
longstanding requirements that federal contractors:

• Invite applicants and employees to voluntarily self-identify as individuals with disabilities.
• Analyze progress toward the 7% disability utilization goal across job groups.

The proposal would keep nondiscrimination and general affirmative action obligations but remove
the quantitative utilization goal framework and some of the more detailed data-driven
requirements. Supporters argue this could simplify compliance and reduce administrative burdens;
critics worry it would weaken accountability and make disability inclusion harder to measure.

2. VEVRAA: Structural Revisions, Fewer Changes to Core Obligations

The VEVRAA NPRM focuses more on structural updatesremoving references to EO 11246 and relocating
enforcement provisions into the VEVRAA regulations themselvesrather than dramatically changing
veterans’ affirmative action obligations.

Data collection and outreach expectations for protected veterans largely remain intact
for now, including:

• Mandatory job listings with employment service delivery systems.
• Annual hiring benchmark analysis.
• Self-identification invitations for applicants and employees.

3. EO 11246: Proposed Rescission of Longstanding DEI Regulations

In a sweeping move, the Department of Labor has proposed rescinding the regulations implementing
EO 11246, which historically required affirmative action and nondiscrimination on the basis of
race, color, religion, sex, sexual orientation, gender identity, and national origin for federal
contractors.

Though this article focuses on Section 503 and VEVRAA, contractors can’t fully separate these
proposals; they’re part of a broader reconfiguration of how affirmative action and equal
employment opportunity expectations are framed for the federal contractor community.

Why the Extension Matters: More Than Just 15 Days

The extension isn’t just bureaucratic housekeeping. It came against a backdrop of intense public
scrutiny and strong opposition from many stakeholders who believe the proposed changes would
dismantle progress on disability and veteran inclusion.

Several themes have emerged in early commentary:

• Data vs. burden: Some contractors appreciate the idea of fewer paperwork-heavy requirements, while advocacy groups warn that “what gets measured gets done”and what doesn’t get measured tends to vanish quietly.
• Signal to employees: The self-ID process and utilization goals send a clear internal message that disability inclusion is a priority. Eliminating those tools might be seen as stepping back from that commitment.
• Aligning with other agencies: The proposed transfer of Section 503 and VEVRAA enforcement to EEOC and VETS, along with other changes, raises questions about how consistent enforcement will be across agencies going forward.

The bottom line: If your organization has strong viewspro, con, or somewhere in betweenthis
extension is your chance to refine your arguments and get them onto the record.

What Contractors Should Do Before the New Comment Deadline

Extra time only helps if you use it strategically. Here’s a practical, human-friendly roadmap to
making the most of the extended comment period.

1. Assemble a Cross-Functional Comment Team

This is not a “just send it to Legal” moment. The proposed changes touch HR, talent acquisition,
diversity and inclusion, data analytics, and operations. Consider bringing together:

• HR or talent acquisition leaders responsible for recruiting and self-ID processes.
• DEI or accessibility team members who understand disability and veteran inclusion priorities.
• Legal or compliance staff familiar with OFCCP audits and AAPs.
• Data or HRIS specialists who can speak to reporting burdens and feasibility.

A short working sessioneven a 60–90 minute virtual meetingcan help your organization decide
its overall position and prioritize issues for comment.

2. Map Your Current Obligations vs. Proposed Changes

Use your existing AAPs for individuals with disabilities and protected veterans as a reality
check. What are you doing today because Section 503 and VEVRAA require it, and what do you do
because it’s simply the right thing for your workforce?

For example:

• If the 7% utilization goal were removed, would you still track disability representation?
• If self-ID invitations became optional, would you continue them to support internal DEI goals?
• Would changes to benchmarks or data reporting actually reduce workload, or would internal
  stakeholders still ask for the same analytics?

Many contractors already treat the Section 503 utilization goal and VEVRAA benchmarks as business
intelligence tools, not just compliance obligations. Removing regulatory requirements might not
eliminate the practical need for that information.

3. Decide Whether to Submit Organizational Comments, Support Trade Groups, or Both

Not every contractor needs to draft a 20-page legal brief. Reasonable strategies include:

• Submitting your own comment focused on a few key issues where your organization has unique perspectives (such as the impact on people with disabilities or veterans in your industry).
• Supporting or co-signing comments from trade associations, higher ed coalitions, or industry groups that are preparing comprehensive submissions.
• Providing real-world examples instead of legal jargonagencies often find operational, concrete stories particularly persuasive.

4. Keep Your Current Compliance Program Fully Intact

While the comment period is open, the existing regulations remain in effect. OFCCP, and soon
other agencies, still expect:

• Current, updated AAPs for individuals with disabilities and protected veterans.
• Documented outreach and recruitment activities.
• Self-ID invitations and tracking processes, as applicable.

Recent agency guidance and law firm alerts emphasize that contractors should not scale back their
disability and veteran compliance efforts based on proposed rules alone.

5. Plan for Multiple Future Scenarios

Regulatory change rarely unfolds in a straight line. OFCCP could:

• Finalize the rules as proposed.
• Modify them significantly based on public comments.
• Delay or phase in changes.

Smart contractors are scenario-planning nowidentifying what they would maintain voluntarily
(such as internal disability representation goals) even if the rules become less prescriptive.

Real-World Experiences: How Organizations Are Responding

To give this more texture, let’s look at how different types of federal contractors are using
the extended comment period. These examples are composite scenarios based on common patterns
reported by law firms, consultants, and industry groupsnot descriptions of any single company.

Case Study 1: A Mid-Sized Defense Manufacturer

A mid-sized defense contractor with 1,200 employees and multiple contracts over the VEVRAA
threshold has long relied on detailed workforce analytics. The HR team tracks disability and
veteran representation by job group, location, and career level, going beyond what the current
Section 503 and VEVRAA rules require.

When the NPRMs dropped, the compliance director’s first reaction was relief: “Fewer utilization
analyses? Fewer forms? Sign me up.” But within a week, the director realized that leadership,
the DEI council, and even some employee resource groups still wanted the same data for business
reasonsretention, culture, and employer branding.

The company used the extended comment period to:

• Draft a short comment letter emphasizing that while they support reducing duplicative recordkeeping, they rely heavily on self-ID and disability utilization metrics to guide internal strategy.
• Encourage their industry association to highlight how predictable, consistent data requirements help companies benchmark disability and veteran inclusion across the sector.

The practical takeaway: even contractors who appreciate reduced regulatory burden are telling
OFCCP they don’t want to lose the tools that help them drive real inclusion outcomes.

Case Study 2: A Large Public University

A large research university with thousands of employees and multiple federal grants has always
treated Section 503 and VEVRAA obligations as part of its broader equity and accessibility
mission. The university has robust disability services, veteran support centers, and a strong
culture of accommodation.

When the proposed changes surfaced, the university’s equal opportunity office convened a
cross-functional meeting with HR, counsel, and representatives from disability and veteran
support programs. Their consensus:

• The proposed elimination of the 7% utilization goal sends the wrong message about disability inclusion.
• Self-ID is a critical tool for understanding who is in the workforce and what support they need.
• Students and employees expect the institution to stay ahead of, not just compliant with, federal requirements.

Using the extended deadline, the university:

• Prepared a detailed organizational comment describing how the current rules have helped them build a more inclusive environment.
• Submitted stories (appropriately anonymized) showing how self-ID led to improved accommodations, training, and resource allocation.
• Collaborated with higher education associations working on sector-wide comment letters.

The lesson here: mission-driven organizations often view these regulations as a floor, not a
ceiling, and are using comments to argue against rolling back tools that have supported progress.

Case Study 3: A Tech Contractor New to AAPs

A rapidly growing tech firm just crossed the threshold requiring written AAPs under Section 503
and VEVRAA. The timing is, frankly, terrible. As they’re building their first programs, the rules
might soon change.

Instead of freezing in confusion, the company:

• Worked with an outside consultant to build AAPs under the current rules because they’re enforceable today.
• Joined webinars from law firms and consulting groups explaining the NPRMs and comment strategies.
• Submitted a concise comment letter explaining the challenges of onboarding into a compliance framework that may shift midstream.

For newer contractors, the extended comment period is a chance to say, “Here’s what helps us
build good programs, and here’s what just adds confusion.”

Final Thoughts: Use the Extra Time, Even If You’re Busy

The extension of the comment period for Section 503 and VEVRAA is more than a scheduling tweak.
It’s an invitation for the federal contractor community to help shape the future of disability
and veteran inclusion requirements.

Whether your organization loves, hates, or is simply puzzled by the proposed changes, this is
the moment to speak up. A thoughtful, concrete commentgrounded in your real-world experience
with AAPs, audits, self-ID processes, and inclusion goalscan carry real weight.

And remember: regardless of where the rules land, building workplaces that genuinely welcome
individuals with disabilities and protected veterans is not just a compliance obligation. It’s a
business advantage and a statement about who you are as an employer.