The Office of Management and Budget (OMB) has approved a three-year extension for Section 503-related recordkeeping requirements, including the CC-305 Voluntary Self-Identification of Disability form. This compliance alert considers the extension in the wider context of proposed revisions and agency shake-ups.
Summary
On July 16, the Office of Information and Regulatory Affairs (OIRA)’s Office of Management and Budget issued a notice of action concerning the OFCCP’s Section 503 recordkeeping requirements. This notice mandated an extension, without change, through to July 31, 2029. Consequently, federal contractors should continue to use the CC-305 Voluntary Self-Identification of Disability form and maintain all records required under Section 503 of the Rehabilitation Act of 1973.
In recent months, these collections have received only short-term extensions. Last year, the OFCCP proposed several major changes to Section 503, including a requirement for contractors to invite applicants and employees to self-identify their disability status and reach certain utilization goals. During the public comment period, the agency received over 600 comments, many of which were critical of the plans.
The OFCCP has not issued a final rule or commented on how it intends to proceed, but the extension does seem to indicate that the agency is now inclined to maintain Section 503 self-identification and at least some elements of the existing data collection framework.
Who Is Impacted and What Actions Are Required?
Until the OFCCP’s proposed revisions are resolved, we cannot know for certain whether revisions will be made to the Section 503 obligations—the extension doesn’t prevent the OFCCP from changing its requirements at any point in the next three years. Nonetheless, federal contractors should continue to:
- Use the CC-305 form to gather disability self-identification data
- Maintain all records currently required by Section 503 regulations
- Stay tuned for further announcements on potential Section 503 changes
How Affirmity Can Help
Clean data, well-documented processes, and rigorous analysis remain the cornerstones of effective workforce compliance and proactive improvement. Affirmity is on hand to assist with the following solutions:
- Workforce compliance services, including Section 503, VEVRAA, EEO-1, and VETS-4212
- Workforce analysis software and services
- Compensation and pay equity analysis
- Risk assessment services covering DEI programs, AI use, and more
Protect your organization from shifting agency priorities: Contact our team of experts today.
About the Author
Since joining Affirmity in 2022, Mary Boley has become a trusted consultant, partnering with organizations across diverse industries to navigate workforce compliance and reporting requirements. She specializes in EEO-1, VETS-4212, California and Illinois Pay Data Reporting, Minnesota State Reporting, Affirmative Action Programs (AAPs), and Workforce Insights reports. Known for her analytical expertise and attention to detail, Ms. Boley helps clients meet evolving federal and state compliance obligations with confidence. She also contributes to the continuous enhancement of Affirmity’s consulting services through active participation in ILG meetings and internal initiatives that support innovation and client success.