--- title: ADP HR Compliance Update description: The U.S. Department of Labor's Office of Federal Contract Compliance Programs has revised the regulations implementing Section 503 of the Rehabilitation Act. --- [![ADP® logo](https://sbshrs.adpinfo.com/hs-fs/hubfs/Logo/ADP_logo.png?width=55&height=25&name=ADP_logo.png "ADP® logo")](https://www.adp.com/) - [Tip of the Week](https://sbshrs.adpinfo.com/blog) - Topics - [Compliance](https://sbshrs.adpinfo.com/blog/topic/compliance) - [Employee benefits](https://sbshrs.adpinfo.com/blog/topic/employee-benefits) - [Hiring and onboarding](https://sbshrs.adpinfo.com/blog/topic/hiring-and-onboarding) - [HR101](https://sbshrs.adpinfo.com/blog/topic/hr101) - [Nondiscrimination](https://sbshrs.adpinfo.com/blog/topic/nondiscrimination) - [Pay](https://sbshrs.adpinfo.com/blog/topic/pay) - [Performance management](https://sbshrs.adpinfo.com/blog/topic/performance) - [Policies](https://sbshrs.adpinfo.com/blog/topic/policies) - [Termination](https://sbshrs.adpinfo.com/blog/topic/termination) - [Training and development](https://sbshrs.adpinfo.com/blog/topic/training-and-development) - [Workplace safety](https://sbshrs.adpinfo.com/blog/topic/workplace-safety) - [Webinars](https://sbshrs.adpinfo.com/hrwebcasts) - [Podcast](https://hrpreneur.podbean.com/) - Resources - [Newsletter](https://sbshrs.adpinfo.com/newsletter) - [ACA Reporting Road Map](https://sbshrs.adpinfo.com/aca-road-map) - [FLSA & Overtime Rule Guide](https://sbshrs.adpinfo.com/flsa) - [COVID-19 Resource Center](https://sbshrs.adpinfo.com/covid19) # Compliance Update ## U.S. Department of Labor Revises Disability-Related Requirements for Federal Contractors Under Section 503 Posted on: September 3, 2026 | ### **Key Takeaways** **Impacted Employers:** Federal contractors and subcontractors covered by Section 503 of the Rehabilitation Act of 1973. **Effective Date:** Many of the changes take effect September 21, 2026. **Summary:** The U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) has revised the regulations implementing Section 503 of the Rehabilitation Act. The final rule eliminates disability self-identification requirements, related disability applicant and hiring data collection requirements, and the 7% disability utilization goal and associated analyses for covered federal contractors. However, disability nondiscrimination obligations remain in place, and covered contractors may still be required to maintain affirmative action programs where applicable. **Next Steps:** Covered employers should review recruiting, hiring, onboarding, and affirmative action compliance practices and update policies, forms, and systems as necessary before the rule's effective date. | | --- | ### The Details Effective September 21, 2026, covered federal contractors will no longer be required to: - Ask applicants to voluntarily self-identify as having a disability before or after a job offer. - Conduct periodic disability self-identification surveys of employees. - Provide interim reminders allowing employees to update disability status. - Use OFCCP Form CC-305 for disability self-identification purposes. In addition, covered federal contractors will no longer be required to: - Measure workforce representation against the 7% disability utilization goal. - Conduct annual disability utilization analyses. - Develop action-oriented programs solely because disability representation falls below the former 7% utilization goal. The rule also removes disability-related applicant and hiring data collection requirements that were added as part of the 2013 Section 503 regulations. Employers generally should continue current compliance practices until the rule takes effect on September 21, 2026. #### *Nondiscrimination Requirements Remain* Notably, Section 503's nondiscrimination requirements remain in effect. Covered contractors must continue to provide equal employment opportunities to qualified individuals with disabilities and maintain required written affirmative action programs if they have 50 or more employees and a qualifying federal contract or subcontract of $50,000 or more. Separately, the OFCCP issued additional final rules that make technical and conforming changes following the rescission of Executive Order 11246. Those rules formally [rescind the regulations implementing Executive Order 11246](https://www.federalregister.gov/documents/2026/08/21/2026-17114/rescission-of-executive-order-11246-implementing-regulations) and make related [updates to OFCCP's regulations concerning protected veterans](https://www.federalregister.gov/documents/2026/08/21/2026-17116/modifications-to-the-regulations-implementing-the-vietnam-era-veterans-readjustment-assistance-act). #### *Veteran Requirements Remain* Importantly, covered federal contractors’ obligations relating to protected veterans remain. These include requirements to ensure nondiscrimination and take affirmative action, maintain a written affirmative action program, ask applicants to voluntarily self-identify as protected veteran in the pre-offer and post-offer stages of the hiring process, collect related data, and analyze whether they meet the hiring benchmark that they established. ### Next Steps Before September 21, 2026, covered federal contractors should: - Review applicant tracking, recruiting, and onboarding systems. - Remove disability self-identification processes and forms that will no longer be required on the effective date. - Update affirmative action program documentation and compliance procedures. - Discontinue disability utilization-goal analyses on the effective date. - Maintain disability nondiscrimination, reasonable accommodation, and accessibility policies and practices. | ## **Small Business Webinars:  Common HR Mistakes to Avoid** **![2025 ADP\_Icons\_Flexibility](https://sbshrs.adpinfo.com/hs-fs/hubfs/SBS%20Communications/Icons/2025%20ADP_Icons_Flexibility.png?width=90&height=90&name=2025%20ADP_Icons_Flexibility.png)** Watch our two-part series of 30-minute webinars on demand to learn about common problematic HR practices to avoid. [![Watch On Demand](https://no-cache.hubspot.com/cta/default/342754/interactive-214778010549.png)](https://sbshrs.adpinfo.com/hs/cta/wi/redirect?encryptedPayload=AVxigLIaAYgi7k1rEil1yKtESwPj95PH7sgaqt%2BzPUv5MjwCAdEvFDiSx42lClTDtAh89VqGPQ86mwf3amX1COgwTkBPYOrBbT5VdzR5LbREVG3LMwwz1OikOhon4axohX%2BVWHDY2MlhNRcjCah%2Bbx8WwbzYr%2BQpBSo6VQvH5fnDDNfqzeSP4PBZ07Vi7%2BtQbTrW1NKomYH3Bj9QDNDmsdgzjwwxFG7pXLU9RhImww9maXsnHmydcGPHidJOwhqRQLuCbZc8%2FsHIfoXip1wOZw%3D%3D&webInteractiveContentId=214778010549&portalId=342754&hsLang=en) | | --- | | Have HR Questions? If you’re a RUN Powered by ADP® client with the Complete Payroll & HR Plus bundle or HR Pro Payroll & HR bundle, contact the HR HelpDesk for assistance. Don’t have these RUN bundles? Consider upgrading to get access to the HR HelpDesk. Call (833) 501-4732 and our team will help you explore your bundle options! | | --- | This content is provided with the understanding that ADP is not rendering legal advice or other professional services and is current as of the published date. Use of this content is subject to the RUN Powered by ADP® Terms of Use.  ADP, the ADP logo, HR{preneur}, RUN Powered by ADP and Always Designing for People are registered trademarks of ADP, Inc and its affiliates. All other marks are the property of their respective owners. Copyright © 2026 ADP, Inc. All rights reserved. [Privacy at ADP](https://www.adp.com/privacy.aspx)