OFCCP

OFCCP Compliance Review 2025: Updates Federal Contractors Must Know

Written by OFCCP.com | Dec 19, 2025 3:52:28 PM

The past year brought significant change for the Office of Federal Contract Compliance Programs (OFCCP). New rules were rolled out, existing regulations were rolled back, enforcement was halted in some areas and resumed in others, and leadership changed throughout the administration. All of this culminates to be an uncertain future for the OFCCP as we head into the new year. With all the shifts and changes, we thought it would be helpful to recap the key OFCCP updates from 2025 that you need to know.

Overview of OFCCP Compliance Changes in 2025

Recruiters and Compliance Officers working for federal contractors are familiar with how difficult it can be to stay up to date with the latest OFCCP rules and regulations. However, as a federal contractor or subcontractor, failure to stay current can expose your organization to legal risks, operational missteps, and audit nightmares.

This past year was more turbulent than usual, leaving many federal contractors wondering which obligations remain in force, and which do not.

  • January kicked off with the Rescission of Executive Order 11246 and the pausing of enforcement activity.
  • In July, the OFCCP then announced that they would resume enforcement activities under Section 503 of the Rehabilitation Act and Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA).
  • The OFCCP announced the new VEVRAA hiring benchmark in August, followed by a leadership change in September. Finally, in October, increased jurisdictional thresholds for Section 503 and VEVRAA were announced.
  • Of course, looming throughout all of this is the proposed FY 2026 budget and what that means for the future of the OFCCP.

Let’s break down these OFCCP updates from 2025 and how you can prepare for 2026.

Rescission of EO 11246 

On January 21, 2025, President Trump issued an Executive Order titled, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” which required significant changes to the OFCCP and federal contractor obligations with respect to recruitment, hiring and employment on the basis of race, color, sex, sexual preference, religion or national origin.

The Order rescinded Executive Order 11246, which had for decades provided the foundation for these federal contractor obligations, and instructed the OFCCP to end certain diversity and affirmative action requirements for federal contractors.

Shortly after this, the Department of Labor (DOL), directed the OFCCP to stop all investigative and enforcement activity under EO 11246. This included pausing or closing pending audits.

The rescission of EO 11246 meant that certain long standing affirmative action requirements no longer applied. While reducing the obligations of federal contractors, this led to confusion around what was still required.

OFCCP Reduces its Workforce

In May, the OFCCP laid off about 90% of their staff, going from almost 500 employees down to just 50 and closing all but 4 of their offices. The division tasked with conducting statistical analysis was eliminated and the remaining five-person policy division would be focused on changes to reflect the removal of EO 11246.

The changes left federal contractors with questions about the future of the agency and its ability to ultimately conduct audits and enforcement activity.

Enforcement Resumed for VEVRAA and Section 503

Federal contractors spent the next several months adjusting to the new normal. On July 2 2025, the DOL issued an order lifting the temporary abeyance on enforcement activities under Section 503 and VEVRAA.

The OFCCP resumed processing complaints based on disability and protected-veteran status. Affirmative Action Plan (AAP) certification remains closed but federal contractors are encouraged to keep Section 503 and VEVRAA plans current and audit-ready.

The OFCCP’s enforcement focus is now narrowed to disability and veteran-related compliance under Section 503 and VEVRAA, while E.O. 11246 obligations remain rescinded.

VEVRAA Benchmark

The OFCCP released its new 2025 VEVRAA national benchmark, effective as of July 30, 2025. The hiring benchmark represents the percentage of total hires who are protected veterans that the contractor seeks to hire in the following AAP year. The new benchmark is 5.1%, down from 5.2% the year before.

Combined with resumed enforcement early in the month, the benchmark update served as a reminder that, despite speculation earlier in the year, federal contractors and subcontractors are still obligated to fulfill obligations.

Ashley Romanias Steps in as OFCCP Director

A leadership change was added to the list of OFCCP compliance changes in September. It was announced that Catherine Eschbach would be leaving her role as the Director of the OFCCP for a role at the EEOC and that Ashley Romanias would be taking her place. Eschbach is credited with reorienting the OFCCP around affirmative action, DEI, and EO 11246 obligations. While Romanias has now stepped in as OFCCP Director, it remains unclear what that role might look like in the coming year.

Increase to Thresholds for VEVRAA & Section 503

As of October 1, 2025, the OFCCP raised the jurisdictional thresholds that determine which contractors must comply with Section 503 and VEVRAA.

New Coverage Thresholds (Effective Oct 1, 2025)

  • Section 503 of the Rehabilitation Act
    • Old threshold: $15,000
    • New threshold: $20,000
    • AAP requirements still apply to contractors with:
      • 50+ employees, and
      • At least one contract of $50,000 or more
  • VEVRAA (Vietnam Era Veterans’ Readjustment Assistance Act)
    • Old threshold: $150,000
    • New threshold: $200,000
    • AAP requirements now apply to contractors with:
      • 50+ employees, and
      • At least one contract of $200,000 or more

These new thresholds potentially reduce the number of contractors that fall under Section 503 and VEVRAA obligations.

Technology and Automation Considerations

Given shifting federal contractor compliance requirements, many contractors are turning to automated tools and compliance-management platforms to stay ready without overburdening HR teams. An integrated compliance management platform can unify your recruitment and compliance activities for complete visibility, time saving efficiency, and peace of mind that you’re audit ready, regardless of changing obligations.

Compliance obligations may be narrower, but they’re still critical and automation helps ensure accuracy and readiness.

Looking Ahead: OFCCP Compliance Trends & Changes for 2026

The fate of the OFCCP remains unclear as we head into 2026. The proposed FY 2026 budget would eliminate funding for the OFCCP, moving enforcement of disability and veteran protections to EEOC and VETS. The House version of the bill proposes no funding for the OFCCP, while the Senate version of the bill proposes reducing funding for the OFCCP. As a final budget hasn’t been passed, the OFCCP’s future remains undecided.

What you can do now to prepare for 2026 OFCCP compliance changes

2025 was a year of transformation for OFCCP compliance. EO 12246 obligations are gone, but Section 503 and VEVRAA remain active and enforceable.

Here’s what you can do to prepare for next year:

  • Review your current workforce size and contract portfolio to assess coverage under updated thresholds.
  • Maintain (or set up) audit-ready recordkeeping for disability and veteran outreach, hiring, and job postings.
  • Evaluate compliance technology tools that support recordkeeping, time saving automation, and audit readiness. Consider how these vendors serve needs outside of compliance as we wait to hear what the future of the OFCCP will be.
  • Keep an eye on emerging 2026 rulemaking and guidance, including the budget process. Subscribe to OFCCP updates.

 

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