On July 16, 2026, the Office of Management and Budget (OMB) approved a three-year extension of the Office of Federal Contract Compliance Programs’ (OFCCP) information collection requirements under Section 503 of the Rehabilitation Act of 1973.

The approval covers the CC-305 Voluntary Self-Identification of Disability form and related recordkeeping requirements for federal contractors. It continues the current collection without change through July 31, 2029.

OMB’s approval comes as the OFCCP’s proposed revisions to its Section 503 regulations remain pending. In July 2025, the agency proposed scaling back several federal contractor obligations related to individuals with disabilities, including eliminating the disability utilization goal and related data analysis requirements. The OFCCP later sought comments on withdrawing the voluntary self-identification form and associated information collection requirements.

The OFCCP has not issued a final rule or otherwise announced how it intends to proceed with its proposed changes. The extension does not resolve the future of the proposed regulations or prevent the OFCCP from changing the requirements before July 2029. It may, however, signal that the agency intends to preserve the existing data collection framework for now.

Federal contractors should continue using the CC-305 form and maintaining the records required by the current Section 503 regulations unless and until the OFCCP issues further guidance or finalizes regulatory changes.

If you have questions about the recent extension and how it may affect your organization, contact a Jackson Lewis attorney.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Laura A. Mitchell Laura A. Mitchell

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating…

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating legal risk. Laura is a guiding force in the firm’s most specialized and technical practice areas where she leverages an analytics-focused approach to partner with her clients in building legally compliant programs around which they can anchor their workplaces achieving productivity and stability.

Laura understands that creating a competitive advantage for employers in today’s workplace involves using a data-driven approach to counsel companies on the development of proactive and equitable non-discriminatory practices in hiring, promotions, separations and pay—and where advancements in technology can create both opportunities for efficiencies and risk that can be measured. Committed to putting her clients’ organizational goals first and foremost while balancing legal risk, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication. Staying the course with employers across their organizational journey while balancing legal compliance obligations throughout their employees’ lifecycle ensures Laura’s position as a go-to resource.

Laura works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize the combined vision of legal compliance, increased productivity and economic growth enhanced by a focus on pay equity.  As part of the pay equity journey, she advises employers on the evolving pay transparency landscape, working to align compliant practices with the practical realities of the business world.

Laura partners closely with government contractors to understand, implement and demonstrate compliance with their EEO regulatory and compliance obligations. She also works closely with non-government contractor clients to conduct risk assessments of their programs, policies, and training to align with federal and state anti-discrimination requirements.

Laura is the editor and a principal contributor of the GovCon Employment Exchange blog and presents on pay equity and government contractor obligations. To round out her days, Laura enjoys spending time with her family and friends attending sports events, working out, riding her bike, playing pickleball and taking in Colorado’s incomparable sunsets.