Affirmative Action Plans: OFCCP Removes Disability Self-ID and 7% Utilization Goal Requirements

On August 21, 2026, the Office of Federal Contract Compliance Programs (OFCCP) published a final rule amending Section 503 of the Rehabilitation Act of 1973. Section 503 applies to federal contractors and subcontractors, and prohibits discrimination in employment against individuals with disabilities and requires federal contractors and subcontractors to take affirmative action to recruit, hire, promote, and retain these individuals.

Beginning September 21, 2026, the following changes will take effect:

• Contractors and subcontractors will no longer be required to invite applicants and employees to voluntarily self-identify as having a disability. Previously, contractors were required to invite applicants to self-identify at certain stages of the hiring process and to survey employees at least once every five years.
• Contractors and subcontractors will no longer be required to conduct a utilization analysis comparing the percentage of individuals with disabilities in each job group (or workforce, if applicable) against the seven percent utilization goal.

Contractors should review their AAP processes and forms to ensure they discontinue the disability self-identification process and utilization analysis once the new rule takes effect. Other Section 503 requirements remain in place, including applicable affirmative action and outreach obligations. Additionally, contractors and subcontractors with a September 1 AAP plan date are still required to complete the seven percent utilization analysis for September 1, 2026, because their plan date falls before the September 21 effective date.

Cascade is monitoring these changes and will notify employers of any additional changes.

Please reach out to us with any questions!