VEVRAA compliance requires federal contractors to take affirmative action to recruit and hire protected veterans, post jobs to state job banks, and meet an annual hiring benchmark. If you're trying to figure out what that means in practice, a lot of the guidance online is out of date. Between enforcement resuming after a period of abeyance, a new hiring benchmark, and updated contract thresholds, the rules look different in 2026 than they did a year ago.
This post covers the current state of VEVRAA compliance: who it applies to, what it requires, and what's changed.
What Is VEVRAA?
The Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) prohibits federal contractors and subcontractors from discriminating against protected veterans in employment. It also requires them to take affirmative action to recruit, hire, promote, and retain those veterans.
The law was originally signed in 1974 and updated most significantly by the Jobs for Veterans Act in 2002, which expanded the categories of protected veterans and added affirmative action requirements. Today, VEVRAA is enforced by the Office of Federal Contract Compliance Programs (OFCCP) within the Department of Labor.
Protected veterans under VEVRAA include:
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Disabled veterans
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Recently separated veterans (within three years of discharge)
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Active duty wartime or campaign badge veterans
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Armed Forces service medal veterans
Who Does VEVRAA Apply To?
VEVRAA compliance obligations apply to federal contractors and subcontractors whose contracts meet certain dollar thresholds. As of October 1, 2025, those thresholds were updated.
Current thresholds (effective October 1, 2025):
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$200,000 or more in federal contracts — basic VEVRAA nondiscrimination and affirmative action obligations apply
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$200,000 or more in federal contracts AND 50 or more employees — a written Affirmative Action Program (AAP) is also required
The threshold was previously set at $150,000. If your organization was borderline under the old figure, it's worth confirming whether your current contracts still trigger VEVRAA obligations. Thresholds are adjusted periodically for inflation, so check the current figures with your legal team or directly on the DOL's OFCCP website.
What VEVRAA Actually Requires
VEVRAA compliance obligations fall into four areas. Here's what covered contractors are expected to do:
Job posting and outreach
You're required to list all job openings with the appropriate State Employment Service Delivery System (ESDS). The only exemptions are executive and top management positions, internal-only postings, and positions lasting three days or fewer. Beyond state job banks, contractors must conduct documented outreach to veteran populations, establishing and maintaining relationships with local veterans' employment representatives, veterans' service organizations, job centers, and similar resources.
Affirmative action and hiring benchmarks
Contractors with 50+ employees and $200,000+ in contracts must maintain a written AAP for protected veterans. That plan needs to include an annual hiring benchmark, data tracking on veteran applicants and hires, and documentation of outreach efforts.
Self-identification
Contractors must invite veterans to self-identify voluntarily at two points in the hiring process: before an offer is made (pre-offer) and after an offer has been accepted (post-offer). This data is used to track progress against the benchmark.
Recordkeeping
Maintain records of job postings, applications, hires, and outreach activity. The DOL requires contractors to keep these records for a minimum of two years, or three years for contractors with 150+ employees or $200M+ in contracts.
The 2025 VEVRAA Hiring Benchmark
Each year, the OFCCP publishes a national hiring benchmark — the percentage of new hires that should be protected veterans, based on the veteran share of the civilian labor force. This benchmark is not a quota. Missing it doesn't automatically trigger a review, but contractors are expected to use it as a target and document what they're doing to work toward it.
The current benchmark, effective July 30, 2025, is 5.1%.
That's down from 5.2% in 2024 and continues a steady downward trend since the benchmark was introduced in 2014. The decline reflects the shrinking veteran share of the overall labor force, not a signal that VEVRAA compliance enforcement is loosening.
Contractors have two options:
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Use the national benchmark: adopt the 5.1% figure as your target
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Set an individualized benchmark: calculate your own based on the factors in 41 CFR 60-300.45(b)(2), including veteran availability in your recruiting area and the nature of your workforce
Most contractors use the national benchmark unless they have specific reasons to believe their local veteran labor pool differs significantly from the national average.
VEVRAA Enforcement in 2026
The enforcement picture shifted significantly in the past year, and it matters for where contractors stand right now.
In early 2025, OFCCP suspended VEVRAA compliance evaluations as part of broader regulatory uncertainty. That abeyance was lifted in July 2025 and scheduled compliance evaluations resumed. For FY 2026, Congress funded OFCCP at nearly $101 million, rejecting proposals to reduce the agency's oversight role under VEVRAA and Section 503. The agency is active, funded, and conducting reviews.
How to Maintain VEVRAA Compliance
Contractors often struggle when it comes to execution on requirements under VEVRAA: keeping up with posting requirements across every open role, maintaining documentation, and doing outreach that's both genuine and easy to verify. Here are the practical steps:
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Audit your state job bank posting. Are jobs going out to the right ESDS consistently? Gaps here are the most common compliance finding and one of the easiest to close with the right tools.
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Set and document your benchmark. Whether you're using the national 5.1% figure or a custom benchmark, make sure it's written into your AAP and that you're actively tracking progress against it.
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Build real outreach relationships. Outreach requirements aren't satisfied by a one-time email blast. Document ongoing relationships with local veterans' employment representatives and keep those records current.
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Collect self-ID data at both stages. Pre-offer and post-offer self-identification needs to happen consistently across all hiring. Spot-check your process to confirm it's actually running.
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Get documentation back in order. If your organization paused compliance activity during 2025's abeyance period, close those gaps now — before enforcement catches up.
JobTarget's Compliance Suite automates the posting and outreach pieces (state job bank distribution, outreach documentation, and proof storage) directly inside your existing hiring workflow. If you're managing VEVRAA compliance manually, it's worth seeing how much of that work can run automatically. You can also compare VEVRAA compliance software options if you're evaluating vendors.
Frequently Asked Questions About VEVRAA Compliance
VEVRAA compliance refers to a federal contractor's obligations under the Vietnam Era Veterans' Readjustment Assistance Act, including nondiscrimination, affirmative action, veteran outreach, state job bank posting, and annual hiring benchmark tracking. It applies to contractors with federal contracts of $200,000 or more.
Federal contractors and subcontractors with contracts of $200,000 or more must meet basic VEVRAA nondiscrimination and affirmative action requirements. Contractors with $200,000+ in contracts and 50 or more employees must also maintain a written Affirmative Action Program (AAP).
Yes. OFCCP suspended VEVRAA compliance evaluations in early 2025, but enforcement resumed in July 2025 after the abeyance was lifted. Congress funded OFCCP at nearly $101 million for FY 2026, preserving its oversight role under VEVRAA and Section 503.
OFCCP selects contractors for compliance evaluations through neutral scheduling criteria. It's not always triggered by a complaint. Common audit findings include gaps in state job bank postings, incomplete outreach documentation, and missing self-identification data.
Virtually all openings with three exceptions: executive and top management positions, positions filled internally, and positions lasting three days or fewer.
