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Since Executive Order 11246 was rescinded in January 2025, OFCCP compliance for federal contractors rests on two laws: the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) and Section 503 of the Rehabilitation Act. The Office of Federal Contract Compliance Programs (OFCCP) enforces both. This page covers the four areas that decide whether your records hold up: documentation and posting proof, state job bank listing, year round readiness, and veteran and IWD (individuals with disabilities) outreach records. For the product itself, see JobTarget's Compliance Suite page.
The rescission ended a separate set of obligations tied to Executive Order 11246, and the regulations that carried them out are rescinded effective October 26, 2026. VEVRAA compliance and Section 503 compliance remain in place. The Department of Labor's final rule on VEVRAA, effective September 21, 2026, codifies the $200,000 contract threshold that has applied since October 1, 2025. A companion Section 503 rule, effective the same day, ended the requirement to invite applicants and employees to self-identify as an individual with a disability and retired the 7% utilization goal. Outreach and recruitment for individuals with disabilities still apply, so the outreach record now carries more of the weight. JobTarget tracks these changes on its OFCCP final rules summary page.
What does OFCCP compliance require of federal contractors?
OFCCP compliance requires federal contractors to follow VEVRAA once a contract reaches $200,000 and Section 503 once a contract reaches $20,000, which means listing jobs where required and, for contractors with 50 or more employees, doing outreach and keeping records. Contract value decides whether you are covered, and headcount adds a second layer. Every covered contractor lists openings with the state job bank under VEVRAA. Contractors with 50 or more employees, and a contract of $200,000 under VEVRAA or $50,000 under Section 503, also need a written program, which is where the outreach, assessment, and recordkeeping duties sit. DOL’s Section 503 FAQ covers the disability side, and its VEVRAA FAQ covers the veteran side.
Three duties show up again and again. VEVRAA requires you to list openings with the state job bank. For contractors with 50 or more employees, both laws call for outreach and positive recruitment, and both expect you to document that outreach and keep the documents. JobTarget's job posting requirements checklist puts the posting side in plain terms.
Who has to comply with VEVRAA and Section 503?
Federal contractors and subcontractors are covered once a contract reaches $200,000 under VEVRAA or $20,000 under Section 503. Those with 50 or more employees, and a contract of $200,000 under VEVRAA or $50,000 under Section 503, also need a written program with outreach and recordkeeping. JobTarget’s Compliance Suite supports the posting and outreach documentation, but each contractor confirms its own coverage with qualified counsel.
How can federal contractors automate documentation and posting proof?
Federal contractors automate documentation and posting proof by using a system that posts each job to the required state job banks, captures proof of the listing as it happens, and stores that proof for three years, which is what JobTarget's Compliance Suite does with every distributed job. A common weak point in manual compliance is reconstruction. A recruiter posts to a state job bank, closes the tab, and months later no one can show the date or the page. JobTarget's breakdown of the real cost of manual job posting shows how much time hand posting takes before compliance is added.
The regulation requires you to document your activities and retain the documents for 3 years. It does not hand you a template. That leaves the format to you, so build a clear record: job title, requisition number, state, date, time, and an image of the live listing. A timestamped image shows the listing went live, which a submission confirmation alone cannot.
The Compliance Suite also includes Local Outreach, an Activities App, and job performance reports. Those features are described on the OFCCP Compliance Automation page.
How does JobTarget's Compliance Suite capture proof of state job bank posting?
JobTarget's Compliance Suite automatically distributes jobs to state job banks and to sites that reach veterans and people with disabilities. It collects image proofs of each listing with timestamps and stores them for three years. Your team pulls the records from one place instead of rebuilding them from email and browser history.
How do state job bank posting requirements work for federal contractors?
Under VEVRAA, a federal contractor must list its employment openings with the appropriate state employment service delivery system (ESDS). The listing must happen at least at the same time as any other recruitment. The contractor must also tell the ESDS it is a federal contractor seeking priority referrals of protected veterans. The requirement sits in the equal opportunity clause at 41 CFR 60-300.5.
Each state runs its own system, and the right one is the state where the opening occurs. Three kinds of roles are generally outside the requirement: executive and senior management positions, positions filled from within, and positions lasting three days or less. OFCCP.com's guide to state job bank posting for federal contractors covers the exemptions and the common gaps.
The gap that causes trouble is proof. A submission record shows you tried. A timestamped image of the live listing shows it appeared. DOL's VEVRAA FAQ explains what a listing must include, and the answer on remote roles is useful for distributed teams.
Do remote jobs have to be listed with a state job bank?
Yes. For a fully remote role with no fixed duty station, DOL guidance lets a contractor list with an ESDS in any area where qualified candidates might be found. If the posting names a specific location, list with that station's ESDS. JobTarget's Compliance Suite routes each job to state job banks by location.
What do compliance reviewers look for, and how do you stay ready year-round?
VEVRAA and Section 503 call for four records a reviewer can ask to see: proof that you listed openings with the state job bank; a log of veteran and IWD outreach; a yearly assessment of that outreach; and outreach documentation kept for three years. Year-round readiness means producing those records as hiring happens, not when someone asks for them.
How often OFCCP schedules reviews changes over time. What contractors have to keep does not. OFCCP continues to investigate complaints, and when it schedules a compliance evaluation, it names selected establishments on the Corporate Scheduling Announcement List (CSAL) and sends each one a scheduling letter that requests documentation within 30 days. A record built as you hire answers either one the same way. JobTarget's readiness checklist gives your team a way to check where you stand today.
What is a compliance readiness checklist for federal contractors?
A compliance readiness checklist is a self-assessment that walks a contractor through the VEVRAA and Section 503 requirements that get checked. JobTarget's Compliance Readiness Checklist shows where your current process stands today. It does not issue a compliance determination, predict an outcome, or replace advice from qualified counsel.
How do you document veteran and IWD good faith recruiting efforts?
To document veteran and IWD good faith recruiting efforts, log each outreach activity with the date, partner, method, and result, assess the prior twelve months once a year, and keep the records for three years. Both the VEVRAA regulation and the Section 503 regulation call for this documentation. The scope of outreach depends on your size and resources, and the rule lists examples.
The examples are practical. For veterans, they include veterans' employment representatives and local job centers. For individuals with disabilities, they include vocational rehabilitation agencies, one stop career centers, and disability organizations. JobTarget's VEVRAA compliance guide explains the veteran side, and its Section 503 guide covers the disability side.
A dated, specific log shows effort, but a general statement of intent does not. Record the requisition or location, the partner and contact, what you sent or asked, the response, and the follow up. At the yearly assessment, ask whether the total effort worked. If it did not, the regulations tell you to add other approaches from the list and to document the change. The OFCCP Compliance Automation page shows where JobTarget keeps these entries.
JobTarget's Local Outreach feature draws on a database of thousands of community organizations and agencies, and the Activities App keeps outreach entries in one place. Both are part of the Compliance Suite.
How does JobTarget's Compliance Suite support veteran and IWD outreach records?
JobTarget's Compliance Suite posts jobs to sites that reach veterans and people with disabilities, keeps image proofs for three years, and allows you to log outreach in its Activities App. Federal contractors must retain outreach documentation for 3 years, so the records remain in one place throughout the period. Local Outreach adds community organizations to contact.
What is the next step for your team?
Start with the readiness checklist, then review your last 10 requisitions and ask whether you can produce the posting proof and the outreach entry for each one. If you cannot, you have found the gap to close first. When you want to see how the Compliance Suite handles it, Get a Demo or read the OFCCP Compliance Automation page.
This page is general information and a self-assessment aid. It is not legal advice. JobTarget does not issue compliance determinations, and no tool guarantees a result. Confirm your obligations with qualified counsel or on the OFCCP website. Last reviewed: [October 2026].
What else do federal contractors ask about OFCCP compliance?
Did rescinding Executive Order 11246 end federal contractor obligations?
No. Executive Order 11246 was rescinded in January 2025, and its implementing regulations are rescinded effective October 26, 2026. That ended a separate set of obligations tied to that order. VEVRAA and Section 503 are separate laws and remain in force. JobTarget's OFCCP resources track both, and the Compliance Suite is built around the VEVRAA and Section 503 requirements.
What is a CSAL notice?
The Corporate Scheduling Announcement List (CSAL) is a list OFCCP publishes on its website naming the federal contractor establishments selected for the next round of compliance evaluations. Each contractor on the list then receives a scheduling letter when its review begins. JobTarget recommends building records as you hire, so readiness never depends on either notice.
Does JobTarget issue compliance determinations?
No. JobTarget provides software and self-assessment tools that document posting and outreach activity. It does not issue compliance determinations or legal advice. Confirm your obligations with qualified counsel or with OFCCP's published guidance, and use the Compliance Suite to keep your records current.
