Compliance Stuff

Navigating the requirements set forth by the Office of Federal Contract Compliance Programs (OFCCP) is essential for ensuring adherence to anti-discrimination and affirmative action regulations and not risking fines and reputational damage. If you’ve been doing this long enough, you know that  OFCCP compliance  rarely feels urgent until someone asks for proof. Proof that jobs were posted correctly. That outreach was documented. That hiring decisions were tracked consistently and can be explained. This guide is built for HR leaders who understand the basics but want a clear-eyed picture of where things stand heading into 2026 and what the teams that sail through audits are actually doing differently. Here’s the short version of what’s changed and what still matters most: Executive Order 11246 was revoked in January 2025 , shifting the active compliance focus to Section 503 and VEVRAA. Coverage thresholds were inflation-adjusted effective October 1, 2025, so it is worth re-check...

On February 3, 2026, President Trump signed a  spending bill  that includes funding for the Department of Labor. The bill allocates  just under $101 million  for the Office of Federal Contract Compliance Programs (OFCCP) for fiscal year 2026 (FY 2026), marking a significant shift from the White House’s  initial budget proposal  to eliminate the agency. The budget approval is approximately $11 million less than the prior year, which is a 10% reduction, leaving a majority of OFCCP’s funding intact. However, based on  recent data , OFCCP’s workforce is about 25% smaller than a year ago. OFCCP is  actively investigating complaints  alleging violations of Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act, and it is clear the agency will survive another fiscal year. However, uncertainty remains about what additional responsibilities the agency may be tasked with in order to utilize the approved budget a...

Quick Hits OFCCP issued an Information Collection Request on January 2, 2026, seeking to revise questions on its complaint and pre-complaint inquiry forms to align with Executive Order 14173. OFCCP issued a renewed Information Collection Request on January 7, 2026, seeking to extend existing recordkeeping requirements under VEVRAA. On January 20, 2026, an appropriation bill was introduced that proposed to fund OFCCP at $100,976,000 for fiscal year 2026 . This appropriation bill passed the House of Representatives on January 22, 2026, and now moves to the Senate for final approval. The future and focus of OFCCP has been the subject of discussion and speculation by the federal contractor community since  Executive Order (E.O.) 14173  was signed in January 2025. In the lead-up to last year’s government shutdown, the House Appropriations Committee proposed to eliminate OFCCP and move oversight obligations to other federal agencies, while the Senate Appropriations Committee propos...

The Office of Federal Contract Compliance Programs (OFCCP) just announced updated jurisdictional thresholds for two key federal affirmative action laws: the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) and Section 503 of the Rehabilitation Act (Section 503). T hese changes, announced on November 25 and driven by the government’s latest inflation adjustments, took effect on October 1, 2025 . Since they may alter which employers are covered going forward, contractors should ensure they are familiar with the new standards – and have a gameplan going forward. Updated Thresholds The “jurisdictional thresholds” are the dollar and size cut‑offs that determine when OFCCP’s Section 503 and VEVRAA rules apply to a contractor.  Given last week’s announcement , the new standards are: Section 503:  The basic coverage threshold has increased from $15,000 to $20,000. VEVRAA:  The coverage threshold has increased from $150,000 to $200,000. These updates do not change t...

In July, the DOJ released updated guidance on what might constitute “illegal DEI” by government contractors under an executive order issued in January. As a result, contractors must now move beyond compliance checklists and toward a strategic, principled and legally sound approach to workforce management, says Constangy partner Cara Crotty, who breaks down the latest developments.   In January, President Donald Trump signed Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” This action rescinded Executive Order 11246, signed in 1965 to provide equal opportunity for women and minorities in hiring by government contractors. The practical implications of this significant shift are just beginning to unfold. Contractors must now recalibrate their  compliance  practices, understand their remaining legal obligations and prepare for a new era of federal scrutiny, one that targets DEI programs as potential sources of unlawful discriminati...