Update Applicable to:	Effective Date
All Covered Federal Contractors and Subcontractors	July 2, 2025

What happened?

On July 2, 2025, the U.S. Department of Labor issued Secretary’s Order 08-2025, lifting the suspension on OFCCP’s enforcement of disability and veteran-related obligations under Section 503 and VEVRAA. This follows a six-month pause triggered by the revocation of Executive Order 11246 and marks a significant shift in federal contractor compliance expectations.

Overview:


What Just Happened?

• OFCCP is back in action: The agency is now authorized to resume enforcement under:
  • Section 503 of the Rehabilitation Act (disability nondiscrimination and affirmative action)
  • VEVRAA – the Vietnam Era Veterans’ Readjustment Assistance Act (veteran nondiscrimination and affirmative action)

• Complaint investigations resume: OFCCP will process all complaints filed or held during the pause.

• Compliance reviews closed: All pending compliance reviews—including those from November 20, 2024, Corporate Scheduling Announcement List (CSAL) will be administratively closed. Formal notifications will be sent to affected contractors.

• The AAP certification portal remains closed, but contractors must still maintain compliant affirmative action programs.

• VAHBP enforcement moratorium extended through May 7, 2027, per Directive 2021-01 Revision 2.

• Uncertainty remains around the status of conciliation agreements related to Section 503 and VEVRAA violations.

Additional Context

• E.O. 11246 enforcement remains prohibited: OFCCP cannot enforce affirmative action obligations based on race, sex, or other categories previously covered under the now-revoked Executive Order.

• OFCCP is pursuing rulemaking to formally rescind E.O. 11246 regulations and remove related references from other rules.

• Despite budget proposals to eliminate OFCCP, the agency continues to:
  • Enforce Section 503 and VEVRAA
  • Issue voluntary information requests.
  • Propose regulatory changes to both laws.

Additional Information:

Steps for Federal Contractors

• Revisit The Disability and Veteran AAPs
  • Ensure the Section 503 and VEVRAA AAPs are current and compliant.
  • Continue availability analyses, goal setting, and self-ID data collection.

• Stay Alert for Complaint Notifications: Be prepared for OFCCP outreach if the organization has complaints filed or pending during the pause or hold.

• Update Compliance Protocols
  • Review internal audit procedures, outreach efforts, and accommodation processes.
  • Re-train staff on what is currently enforceable (Section 503/VEVRAA) vs. what is not (E.O. 11246 categories).

• Watch for AAP Portal Updates: Although certification is paused, monitor OFCCP communications and be ready to certify when the portal reopens.

• Evaluate Risk and Consider a Self-Audit
  • If the business was on the November 2024 CSAL, you will not be audited from that list.
  • If the business had an open audit, expect a formal closure notice.
  • Consider conducting a voluntary self-audit to ensure continued compliance.

• Enforcement: While the regulatory landscape remains in flux, OFCCP has made clear that Section 503 and VEVRAA obligations are fully enforceable. Federal contractors should remain vigilant, compliant, and prepared for further developments.

Source References

• Office of Federal Contract Compliance Programs – Press Release
• Federal Register – 07/11/2025 Public Inspection Issue

Resources

• Executive Order (EO) 14173
• Secretary Order 03-2025 – Cease and Desist all Investigative and Enforcement Under Rescinded EO 11246

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