The US Department of Labor has published a final rule eliminating longstanding disability compliance requirements that have shaped federal contractor obligations for more than a decade.
The rule, published on August 21, 2026, removes the requirement to use Form CC-305, the voluntary disability self-identification form used across federal contracting programmes.
Alongside the form, the Department is eliminating associated disability data-collection requirements and the 7% disability utilisation goal that contractors have long been required to meet.
The changes do not take immediate effect upon publication, with the final rule instead becoming operative on September 21, 2026.
Contractors must continue to follow existing disability self-identification requirements through September 20 and should prepare to discontinue use of Form CC-305 from the following day.
The Office of Federal Contract Compliance Programs (OFCCP) has confirmed that its position is that employer-initiated disability inquiries conflict with the Americans with Disabilities Act, including its prohibition on pre-offer disability inquiries.
OFCCP has also cited ADA restrictions on inquiries directed at current employees as a further basis for eliminating the mandatory self-identification requirement.
The final rule does not sweep away all obligations under Section 503 of the Rehabilitation Act, which continues to prohibit covered contractors from discriminating against qualified individuals with disabilities.
Covered contractors will still be required to take affirmative action to employ and advance qualified individuals with disabilities and must maintain applicable affirmative action programmes.
Contractors must also continue to conduct and evaluate outreach and recruitment efforts, provide reasonable accommodations, and satisfy other remaining Section 503 requirements that the rule leaves intact.
The Section 503 changes form part of a broader deregulatory package that also rescinds regulations implementing Executive Order 11246, references to which are being removed from the relevant regulatory framework.
The broader package additionally modifies regulations implementing the Vietnam Era Veterans’ Readjustment Assistance Act, reflecting a wide-ranging rollback of federal contractor compliance obligations.
OFCCP is making related technical and procedural changes alongside the substantive eliminations, tidying the regulatory framework in light of the revoked executive order.
While the 7% utilisation goal and associated analyses are being removed, contractors should take care not to interpret the rule as a wholesale withdrawal from disability affirmative action compliance.
The rule substantially reduces quantitative compliance obligations but leaves in place the broader affirmative action and nondiscrimination framework that federal contractors have long been subject to under Section 503.