A newly released Government Accountability Office (GAO) report calls on the Department of Labor (DOL) to strengthen its oversight of federal contractors’ compliance with Section 503 of the Rehabilitation Act and provide more guidance to help them meet their obligations. DOL agreed with six of GAO’s eight recommendations but neither agreed nor disagreed with the other two.

GAO’s report, publicly released on Oct. 6, 2026, highlights the value of Section 503 audits as a compliance monitoring tool, even though the Office of Federal Contract Compliance Programs (OFCCP) suspended them in early 2025. OFCCP also paused contractors’ affirmative action program (AAP) certifications, which were previously submitted by contractors through OFCCP’s Contractor Portal. GAO reported that this was done despite the fact that 532 audits conducted by OFCCP between fiscal years 2017 and 2025 found violations of Section 503. Without audits, GAO said, DOL has less assurance that contractors are meeting their obligations to support employment of people with disabilities.

In response, DOL said it has no current plans to resume any contractor certifications or audits, and it is evaluating its compliance activities following recent regulatory changes, including the elimination of disability status self-identification and AAP utilization “goals.”

What This Means for Contractors

While DOL indicated no plans to remove the pause in certifications and audits, future administrations may take note of GAO’s recommendations. Significantly, contractors still have an obligation to maintain written Section 503 AAPs and ensure affirmative action for applicants and employees with disabilities. Although DOL removed the disability self-identification invitation requirement and seven percent utilization goal from its Section 503 regulations in August 2026, other requirements remain. Contractors should review their current AAPs and practices against those requirements while monitoring OFCCP’s response to the report.

If you have questions about your organization’s Section 503 compliance or GAO’s recommendations, contact a Jackson Lewis attorney.

Tags: AAP, Federal Contractor, GAO report, OFCCP, Section 503
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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.

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