The past 14 months have been confusing for federal contractors.
Executive Order 11246 was rescinded in early 2025, ending the race and sex compliance requirements federal contractors had maintained for decades. Those specific obligations are no longer mandated. Media coverage was heavy. The perception followed: OFCCP requirements had been lifted.
That perception is incomplete. And for contractors who act on it, the consequences will be real.
OFCCP is not gone. Two major compliance obligations remain active and enforceable. The audit schedule is larger than it has been in recent OFCCP history. And the agency continues to recover millions of dollars annually from contractors who fail to comply.
Here is what changed, what stayed, and what your organization needs documented right now.
Q: Is OFCCP still active in 2026?
A: Yes. While Executive Order 11246 was rescinded in early 2025, ending race and gender compliance requirements, two significant obligations remain fully in force: Section 503 of the Rehabilitation Act (covering individuals with disabilities) and VEVRAA (covering veterans). Federal contractors subject to these laws must still document recruitment outreach, track applicant data by protected class, and maintain audit-ready records.
Executive Order 11246 required federal contractors to develop and maintain written affirmative action plans addressing race and gender in hiring and promotion. These plans required documentation, good faith recruiting efforts, and specific goals and timetables.
That requirement is gone. Race and gender compliance plans for women and minorities are no longer mandated by federal law. If your organization maintained these plans, you are no longer required to do so by statute.
This was a significant change. It ended decades of compliance obligation. The media covered it that way. But the rescission of this one order does not mean all OFCCP compliance obligations have disappeared. It means that specific obligation has ended.
Other obligations remain.
Section 503 of the Rehabilitation Act of 1973 remains active and fully enforceable. This obligation applies to federal contractors with contracts of more than $20,000 and requires specific, documented outreach and hiring practices for individuals with disabilities (IWD).
Section 503 requires contractors to:
Q: What does Section 503 require federal contractors to document?
A: Section 503 requires contractors to document outreach efforts to individuals with disabilities, maintain records of applicant flow data (who applied, who interviewed, who was hired by disability status), and demonstrate reasonable accommodations were offered during recruiting. These records must be available for OFCCP review during a compliance evaluation.
The compliance requirement is clear. The enforcement risk is real. JobTarget's Compliance Suite is built specifically to capture and organize this documentation so it is audit-ready rather than reconstructed under pressure.
The Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) remains active and fully enforceable. This law requires federal contractors and subcontractors with contracts of $200,000 or more to take specific steps to recruit, hire, and support covered veterans.
VEVRAA requires contractors to:
Both obligations require documentation. Both are actively enforced. And enforcement has intensified as OFCCP has clarified standards for what constitutes "good faith effort" and "adequate documentation".
Q: Does VEVRAA still apply after EO 11246 was rescinded?
A: Yes. VEVRAA is a separate federal law, not an executive order, and its rescission was never on the table. Federal contractors with contracts of $150,000 or more are still required to document veteran outreach efforts, include veteran opportunity language on every job posting, and maintain applicant flow data by veteran status. These obligations are unchanged in 2026.
Here is the current enforcement picture: Congress appropriated approximately $100.98 million to OFCCP for fiscal year 2026, overriding earlier proposals to eliminate the agency. OFCCP remains the primary enforcement body for federal contractor compliance and is funded through September 30th, 2026.
For your organization, five things are now critical.
Audit-ready recordkeeping. You need documentation of every recruitment effort: job postings, where they were distributed, outreach descriptions, dates, and applicant flow data by disability and veteran status. This documentation must be organized for an OFCCP investigator to review, not scattered across emails and spreadsheets.
Written policies. You need documented policies describing your good faith recruitment efforts under Section 503 and VEVRAA. These are not the same as the race and gender compliance plans that were previously required under EO 11246. They are documented commitments covering what channels you use, how you ensure veterans and individuals with disabilities see your postings, and how you handle accommodation requests in recruiting.
Recruiter training. Your recruiting team needs working knowledge of Section 503 and VEVRAA obligations. What documentation is required. What hiring managers can and cannot ask. What outreach constitutes good faith under current OFCCP enforcement guidance.
Data integrity. Your applicant tracking system must capture disability status and veteran status accurately and consistently. If your data is incomplete or unreliable, that itself becomes an audit issue. Clean, complete applicant flow data is not optional.
Automated compliance posting. Every job posting must be sent to the required state job banks and sites targeting veterans and people with disabilities. Manual processes create gaps. JobTarget's Compliance Suite automates posting and retains image proofs for 3 years so every posting is documented.
Here is what your organization needs in place now:
If any of these are missing, you have a compliance gap. If OFCCP audits your organization and these records cannot be produced, you have an enforcement risk.
Maintaining this documentation manually creates real operational risk. Outreach efforts get missed. Records are lost. Applicant flow data is incomplete. And when an audit notification arrives, reconstruction is difficult, time-consuming, and often unconvincing to investigators.
JobTarget's Compliance Suite is built to handle this documentation systematically. It captures recruitment outreach across all required channels, documents efforts at the time they occur, and generates the reports an auditor will request. Image proofs and screenshots are archived for three years, meeting OFCCP recordkeeping requirements.
The goal is not to minimize the compliance obligation. It is to make compliance operationally manageable so documentation exists when it is needed rather than being assembled under audit pressure.
Q: How does JobTarget help federal contractors prepare for an OFCCP audit?
A: JobTarget's Compliance Suite automates recruitment outreach documentation, posts jobs to required state job banks automatically, and archives image proofs for three years. This gives compliance officers and HR teams audit-ready records without manual reconstruction.
The rescission of Executive Order 11246 simplified federal contractor obligations in one specific area. It did not eliminate OFCCP compliance. Section 503 and VEVRAA are active and enforced.
What matters now: federal contractors need clear understanding of what obligations remain, systems to document compliance as it happens, and records that are audit-ready before a notification arrives.
If your organization has not reviewed its Section 503 and VEVRAA posture in the past six months, now is the time.
Ready to ensure your compliance documentation is audit-ready? Explore JobTarget's Compliance Suite or get a demo to see how documentation works in practice.