The OFCCP enforcement picture changed more between January 2025 and April 2026 than it did in the previous 40 years. For six decades, OFCCP operated under Executive Order 11246, which required federal contractors to maintain written affirmative action plans covering race, color, religion, sex, and national origin, to submit to compliance reviews, and to fix any disparate-impact findings. Executive Order 14173, signed January 21, 2025, revoked EO 11246 outright and ordered OFCCP to cease all enforcement activity under it. Federal contractors had until April 21, 2025 to wind down their EO 11246 compliance programs. The agency's remaining jurisdiction (disability protections under Section 503 and veterans' protections under VEVRAA) is narrower than what contractors built for, and compliance teams are still rebuilding around the new scope.
What OFCCP Still Enforces Two statutory programs survived the 2025 changes. Section 503 of the Rehabilitation Act of 1973 prohibits federal contractors and subcontractors with contracts of $15,000 or more from discrimination against qualified individuals with disabilities and requires covered contractors to take affirmative action in employment. The Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) imposes similar obligations for protected veterans on contractors with contracts of $150,000 or more.
Covered contractors still must maintain written affirmative action programs for individuals with disabilities and protected veterans, set annual placement goals (7 percent workforce utilization for individuals with disabilities, for example), submit equal opportunity clauses in subcontracts, and respond to OFCCP compliance reviews and complaint investigations under those two programs.
What Changed With EO 11246 Revocation OFCCP is no longer scheduling or conducting compliance reviews focused on race, sex, or national origin disparities. The agency administratively closed the pending compliance review list released in November 2024. Federal contractors no longer need to maintain the written affirmative action programs for race, color, religion, sex, and national origin that EO 11246 required, and the EEO-1 supplemental reporting obligations tied to EO 11246 are no longer enforced by OFCCP.
What didn't change: Title VII of the Civil Rights Act, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Equal Pay Act, Section 1981, and state-level non-discrimination laws all remain in force. A federal contractor can no longer be cited by OFCCP for disparate impact on race or sex, but the same conduct can still produce an affirmative action -adjacent Title VII claim through the EEOC or private litigation.
Do Federal Contractors Still Need an EEO Policy? Yes. The EEOC still enforces Title VII, the ADA, and the ADEA regardless of contractor status. Federal contractors additionally face OFCCP jurisdiction on Section 503 and VEVRAA and must continue maintaining non-discrimination policies, reasonable accommodation processes, and complaint procedures that cover disability and veteran status.
Compliance Reviews Under the New Scope OFCCP compliance reviews under Section 503 and VEVRAA cover roughly the same ground as the former EO 11246 reviews: a scheduling letter, a desk audit of the contractor's written affirmative action program, an analysis of utilization goals and outreach efforts, and potentially an on-site review and requests for personnel data. The focus areas are narrower (disability accommodations, veteran outreach, utilization goals) but the process is similar.
Contractors typically receive 30 days to respond to a scheduling letter and then enter a multi-stage review that can run six to eighteen months. A finding of material violation can result in conciliation agreements, back pay awards, hiring remedies, and in serious cases contract debarment.
Building an OFCCP Compliance Program for the 2026 Environment Four practices keep federal contractors in compliance under the reduced scope. Maintain Section 503 and VEVRAA affirmative action programs with current utilization analyses and outreach documentation. Retain personnel records covering the statutory look-back period even for protected categories OFCCP no longer enforces, because Title VII and state-law claims still reach back years. Run internal pay equity audits voluntarily, because the protection EO 11246 reviews once provided is gone but the underlying liability under the Equal Pay Act and state equal pay laws hasn't changed. And centralize disability accommodation and veteran outreach tracking, because those are the areas where OFCCP will focus its remaining enforcement attention. AllVoices customers use HR case management and compliance solutions to document accommodation requests, complaint investigations, and disposition decisions in a single audit-ready record. Reference the OFCCP agency page for current scope and enforcement priorities, and the text of EO 14173 for the controlling executive order.
.svg)
.svg)
