Federal contractors have several recruiting and recordkeeping updates to address following a new Department of Labor final rule that took effect September 21, 2026.
The rule changes parts of Section 503 of the Rehabilitation Act, which governs federal contractors’ responsibilities concerning applicants and employees with disabilities. According to an analysis by Sara Strosser of PilieroMazza published by JD Supra, three significant requirements have been eliminated.
What Changed?
Federal contractors are no longer required to:
- Invite applicants and employees to voluntarily self-identify as having a disability.
- Distribute the Voluntary Self-Identification of Disability Form, commonly known as Form CC-305.
- Measure their workforce against the 7% disability utilization goal.
- Conduct the related annual utilization analysis.
- Collect the previously required applicant and hiring data tied to disability status.
The official final rule explains that these changes are intended to align Section 503 regulations with the Americans with Disabilities Act and current executive orders.
What Should Recruiting Teams Do Now?
Federal contractors should review their applicant tracking systems, career sites, application workflows, onboarding materials, and affirmative action plans. Form CC-305 and related disability self-identification questions may need to be removed, while reports built around the former 7% utilization goal should also be updated.
Organizations should not automatically delete previously collected information, however. Existing recordkeeping rules or state and local requirements may still apply, so contractors should consult their legal or compliance teams before removing historical data.
What Still Applies?
These changes do not eliminate every Section 503 responsibility. Covered federal contractors must still avoid disability discrimination, provide reasonable accommodations, meet applicable recordkeeping requirements, and maintain affirmative action programs when required.
The changes also do not affect veteran self-identification obligations under the Vietnam Era Veterans’ Readjustment Assistance Act, or VEVRAA.
The biggest takeaway for recruiting teams: compliance requirements may have changed, but accessible hiring practices and equal employment opportunity still matter. Now is the time to work with HR, legal, compliance, and your ATS provider to make sure your hiring workflows reflect the new rules.
This article is for informational purposes only and should not be considered legal advice.
