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FEDERAL CONTRACTOR COMPLIANCE A Comprehensive Guide for Federal Contractors & Subcontractors. This guide is designed to assist federal contractors and subcontractors in ensuring compliance with the following regulations: Equal Employment Opportunity VEVRAA Section 503 Title VII, ADA, ADEA, GINA, Equal Pay Act, and more! Buidling Better Workplaces Together RESOURCE GUIDE & TOOL KIT
Buidling Better Workplaces Together
TABLE OF CONTENTS About YPHR & Our Compliance Team Overview of Federal Contractor Obligations Overview: VEVRAA & Section 503 Requirements Recommended Vendors & Resources Sample Job Group Worksheet Sample OFCCP Self-Audit Template Self-Identification Forms - IWD & Protected Vets Dispositioning Guide Sample Job Description Template Toolkit/Downloadable Resources: State Specific ESDS List (VEVRAA) Effectiveness Review/Action Plan Template Overview: Affirmative Action Plans Overview: Roles & Responsibilities
ABOUT US Your Partner in HR is a boutique, full-service HR consultancy located in the Cleveland, Ohio area. Founded in 2010 by Sonya Weiland, SHRM-CP, PHR, our mission is to help organizations exceed their goals while also supporting their employees' aspirations. Together, our team of partners and consultants boasts over 100 years of industry experience across various sectors. Our Comprehensive Suite of Services Includes: Fractional HR Compensation Executive Recruitment Talent Acquisition Outplacement Services Leadership & Staff Training/Team Building Coaching Employment Law Legal Services HR Compliance/Federal Contractor Compliance Wealth Management & Retirement Planning Our goal is to be “Your Partner in HR” at every stage of your journey— we are committed to Building Better Places Together!
OUR FEDERAL COMPLIANCE TEAM SONYA WEILAND, SHRM-CP, PHR Founder & President, HR Consultant As the founder of Your Partner in HR, Sonya has focused her career on building positive team environments. Sonya is recognized as a strategic partner to many organizations across the country. Sonya specializes in creating and delivering leadership and employee training programs, and is known for her energetic and interactive training style. MEAGAN PERKINS, SHRM-CP Federal Compliance Practice Leader & HR Consultant With a rich and varied background spanning numerous industry sectors and roles, Meagan has dedicated a significant portion of her career to operations as a leader of people. In January 2026, she stepped into the position of Federal Compliance Practice Leader, showcasing her dedication to becoming a subject matter expert in this domain while assisting our compliance clients in navigating evolving obligations in this field. In the spring of 2025, Your Partner in HR acquired our Federal Compliance Division from the TAMS Group, with whom we have collaborated closely in recent years. Our dedicated team is committed to ensuring that our federal contractor and subcontractor clients maintain full compliance with all requirements at all times, while also keeping you updated on any changes in this area.
OVERVIEW: FEDERAL CONTRACTOR & SUBCONTRACTOR OBLIGATIONS VIETNAM ERA VETERANS’ READJUSTMENT ASSISTANCE ACT (VEVRAA) Federal contractors, subcontractors, and organizations that choose to align with these standards must adhere to various statutes, executive orders, regulations, as well as state and local laws. This includes specific reporting obligations. All these requirements are linked to Equal Employment Opportunity for all protected classes, which is mandated for all employers, irrespective of their contractor status, and encompasses all employment activities, including application, hiring, promotion, termination, and compensation. Here’s a detailed overview of these requirements: TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 The foudational law probibiting employment discrimination based on race, color, religion, sex (including pregnancy, sexual orienation and gender identity) or national origin. AGE DISCRIMINATION IN EMPLOYMENT ACT OF 1967 (ADEA) Prohibits disability discrimination across all employment activities and requires affirmative action for individuals with disabilities. At a basic level, Section 503 applies only to federal contractors/subcontractors with at least $20,000 in federal contracts; affirmative action requirements kick in at 50+ employee headcount and a single contract of $ 50,000 or more. SECTION 503 OF THE REHABILITATION ACT OF 1973 Defines “protected veterans” and prohibits discrimination across all employment activities. Applies to all federal contractors and subcontractors with at least 50+ employees and $200,000 in contractors. Affirmative Action and VETS 42-12 reporting are required. Applies to all employers with 20 + employees, regardless of contractor status and prohibits discrimination across all employment activities for both employees and applicants age 40 and older. EQUAL PAY ACT OF 1963 Prohibits sex-based wage discrimination between men and women performing substantially equal work within the same establishment — jobs requiring equal skill, effort, and responsibility, performed under similar working conditions.
OVERVIEW: FEDERAL CONTRACTOR & SUBCONTRACTOR OBLIGATIONS NONDISCRIMINATION & ANTI-HARASSMENT REQUIREMENTS AFFIRMATIVE ACTION All employers, regardless of contractor status, are prohibited from discrimination across all employment practices (applicant selection, hiring, promotion, termination, compensation, training, etc.). Federal contractors and subcontractors must included protected veterans and individuals with disabilities in their anti-harassment and retaliation policies. Refers to proactive, documented steps an employer takes to identify, recruit, and advance individuals from groups that have hisotrically faced barriers to equal employment opportunity - going beyond simply not discriminating to actively expanding access and outreach. Affirmative action is a PROACTIVE obligation layered ONTOP of Equal Employment Opportunity requirements. Through an annually written plan, federal contractors and subcontractors who meet the required thresholds under VEVRAA and Section 503 are required to actively recruit, track and report on outreach towards protected veterans and individuals with disabilities. Employers should not implement hiring goals/quotas, rather, aspirational targets that they strive to reach through good faith efforts. OFCCP RECORD KEEPING REQUIREMENTS Applications, resumes, and expressions of interest for employment Records of all personnel actions: hires, promotions, demotions, transfers, layoffs, terminations, rates of pay, and selections for training Test results and other selection criteria used in employment decisions Records of impact ratio/adverse impact analyses where conducted Self-identification data (disability, veteran status) collected at pre-offer and post-offer stages Compensation data sufficient to support pay equity analysis Retention Period: Minimum 2 years for most contractors; 1 year for contractors with fewer than 150 employees or contracts under $150,000. If a complaint, charge, or compliance evaluation is filed, records must be retained until final disposition — the standard retention clock doesn't apply once there's active enforcement interest.
Law / Requirement Type What It Requires Threshold 2026 Status NONDISCRIMINATION & AFFIRMATIVE ACTION Title VII, Civil Rights Act of 1964 Statute Prohibits discrimination based on race, color, religion, sex, or national origin All covered employers Active Section 503, Rehabilitation Act of 1973 Statute Prohibits disability discrimination; requires affirmative action for individuals with disabilities (AAP) Basic coverage: $20,000+ AAP: 50+ employees & $50,000+ contract. Active VEVRAA Statute Prohibits protected veteran discrimination; Requires affirmative action 50+ employees & $200,000+ contract Active Executive Order 11246 Executive Order Formerly required race/gender AAPs for hiring and promotion N/A Rescinded Jan. 2025 — no longer required ADEA (Age Discrimination in Employment Act) Statute Protects workers age 40+ All covered employers Active ADA (Americans with Disabilities Act) Statute General disability nondiscrimination; complements Section 503 All covered employers Active PWFA (Pregnant Workers Fairness Act) Statute Requires reasonable accommodations for pregnancy, childbirth, related conditions All covered employers Active Federal Contractor Compliance Reference Guide: A Quick-Reference Overview of Applicable Laws, Thresholds & 2026 Status Updated: July 15, 2026
WAGE & LABOR STANDARDS Davis-Bacon Act Statute Prevailing wage requirements on federal construction contracts Construction contracts Active Service Contract Act (SCA) Statute Prevailing wage/benefits on federal service contracts Service contracts Active Walsh-Healey Public Contracts Act Statute Labor standards for contracts supplying goods to the federal government Supply contracts Active Fair Labor Standards Act (FLSA) Statute Minimum wage and overtime standards All covered employers Active OTHER CONTRACTOR-SPECIFIC OBLIGATIONS IRCA / I-9 Verification Statute Employment eligibility verification All employers Active E-Verify (FAR clause) Regulation Electronic employment eligibility verification required on many federal contracts Per contract clause Active Drug-Free Workplace Act Statute Maintain a drug-free workplace policy Certain federal contracts/grants Active False Claims Act Statute Exposure for falsely certifying compliance All federal contractors Active STATE OVERLAYS (EXAMPLES — VARIES BY STATE) CA Pay Transparency (SB 642, SB 464, Labor Code §432.3) State Statute Pay scale disclosure and pay data reporting Varies Active State EEO Reporting (e.g., IL, MA) State Regulation State-specific workforce/pay data reporting, often layered on EEO-1 Varies by state Active Updated: July 15, 2026 Federal Contractor Compliance Reference Guide: A Quick-Reference Overview of Applicable Laws, Thresholds & 2026 Status
OVERVIEW: AFFIRMATIVE ACTION Equal Employment Opportunity Policy Statement This policy must be signed by an executive officer and posted on bulletin boards and/or company intranet and MUST affirm commitment to affirmative action towards protected veterans and individuals with disabilities. Must include hours when AAP’s can be viewed by employees and should be included in your employee handbooks and must clearly outline reporting system/compliant process. Written Affirmative Action Plans (AAP) are separate, higher-level requirement that applies when you have 50 or more employees and a single contract of $50,000 or more under Section 503 and a single contract of $200,000 or more under VEVRAA. Key elements include: External & Internal Dissemnation of Policy Posting notices, informing of subcontractors, vendors and suppliers regarding the organization’s commitment to equal opportunity and requesting appropriate action on their part. Annual Review of Personnel Processes Workforce and Employment Activities data must be analyzing annually (at a minimum) to ensure fairness/non-discrimination in all employment activities beginning with recruitment through termination. Reasonable Accommodations & Accessibility In compliment to the ADA, reasonable accommodations and clear instructions for requesting, must be available to all applicants and employees. Accessibility of career websites is enforced under this requirement: ensure career pages can be navigated by screen readers, applications don’t rely on visual cues or mouse-based interactions and alternative application pathways for candidates who cannot use standard digital process must be available. Review of Physical & Mental Qualifications Physical and Mental requirements for all positions must be reviewed annually (at a minimum) in order to determine when/where reasonable accommodations can be made. Qualifications must be job-related, tied to actual essential job functions and consistent with business necessity.
OVERVIEW: AFFIRMATIVE ACTION Responsibility for Implementation & Oversight Executive Officer and EEO Official must be designated for oversight and ownership of these requirements. See pages ____ for more information on these roles. Training & Continous Education Hiring Managers, Establishment Leaders, Recruiters, Human Resources, ADA/EEO Officials must be regularly trained on the requirements of equal employment opportunity, reasonable accommodation requests, proper resume review, dispositioning of candidates and employees, understanding military certification translations, etc. Benchmarks VEVRAA establishes an annual “hiring & promotion” benchmark/goal that generally aligns with the nationwide veteran unemployment rate. We typically see this benchmark change toward the July annually. Section 503 establishes a Workforce Utilization Benchmark/Goal of 7% that remains the same year over year, and is determined 100% by employee self-identification. Good Faith Efforts of Positive Recruitment/Outreach & Effectiveness Reviews Voluntary Self-Identification Opportunities Both VEVRAA and Section 503 required documented strategies of positive recruitment and outreach and partnerships towards protected veterans and individuals with disabilities, which will be conducted in good faith effort to meet/exceed benchmarks. Annually, these efforts should be reviewed for their “effectiveness” and outcomes. Additionally, Key elements include: Voluntary Self-Identification opportunities must be presented twice - once during the application stage and secondly at onboarding. These questions are allowed to be “mandatory” but must offer the opportunity to “choose not to self-identify.” See VEVRAA and Section 503 pages for more information on these requirements.
OVERVIEW: ROLES & RESPONSBILITIES Executive Officer: Executive officers (top management/senior leadership) bear ultimate organizational accountability for EEO compliance. Under 41 CFR 60-2.17,Responsibilities include: Visible Commitment & Policy. Issuing a written EEO/Affirmative Action policy statement signed by the chief executive, which must be posted and communicated throughout the organization. This statement demonstrates top management's personal commitment to equal employment opportunity. Providing Authority & Resources. Contractors must assign responsibility and accountability to an official of the organization who has sufficient authority and resources, and must also have the support of, and access to, top management to ensure the effective implementation of EEO obligations and the Affirmative Action Program (AAP) Supporting the AAPs. Actively supporting the development, maintenance, and annual updating of a written AAP for each establishment. Reviewing AAP Results. Top management must be advised of the AAP's effectiveness and any deficiencies, and management at all levels must review the results of internal reports. Ensuring Nondiscrimination. Ensuring that the organization does not discriminate against applicants or employees based on race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or protected veteran status — as required under Section 503, and VEVRAA. Pre-Award Obligations. Prior to the awarding of a contract of $10 million or more, contractors must obtain EEO clearance from OFCCP, a requirement that covers all laws OFCCP enforces. Written Affirmative Action Plans under VEVRAA and Section 503 require the designation of officials who are responsible for oversight and implementation of these programs. The designation of these officials is broken down into two categories:
OVERVIEW: ROLES & RESPONSBILITIES Program Implementation. Serving as the "affirmative action officer," with the responsibility for carrying out the contractor's AAP implementation and EEO commitments. Identifying Problem Areas. Performing an in-depth analysis of the total employment process to determine whether impediments to EEO exist, including evaluating organizational structure, personnel activity (applicant flow, hires, terminations, promotions), compensation disparities, and selection procedures. Developing Action-Oriented Programs. Developing and executing action- oriented programs designed to be inclusive of positive outreach and recruitment efforts towards Protected Veterans and Individuals with Disabilities, as well as conduct an annual “effectiveness review” of those good-faith efforts. Internal Audit & Reporting. Designing and implementing an internal auditing system that periodically measures the effectiveness of the total AAP, including monitoring records of all personnel activity (referrals, placements, transfers, promotions, terminations, and compensation at all levels), and producing internal reports on a regularly scheduled basis. Recommending Corrective Action. Recommending actions to improve progress to top management when audits or reports reveal deficiencies. Coordinating with OFCCP. Serving as the primary point of contact during OFCCP compliance evaluations and complaint investigations, providing access to personnel records, AAP documentation, and supporting data. Complaint Handling. Receiving, investigating, and tracking internal EEO complaints, and referring complaints involving potential violations to the OFCCP regional office as appropriate. Training & Communication. Ensuring managers and supervisors understand EEO obligations, and that the organization's EEO policy and required postings (such as the "EEO is the Law" poster) are properly displayed and communicated. EEO Official / Affirmative Action Officer: The EEO Official (sometimes titled the Affirmative Action Officer or EEO Coordinator) is the designated internal manager responsible for day-to-day implementation. Under 41 CFR 60-2.17, responsibilities include:
Requires covered federal contractors to take affirmative action to employ and advance qualified protected veterans. Coverage applies to federal contractors and subcontractors with a contract of $200,000 or more (threshold increased in October 2025 from $150,000). OVERVIEW: VIETNAM ERA VETERANS’ READJUSTMENT ASSISTANCE ACT (VEVRAA) VEVRAA Defines “Protected Veterans” into 4 Categories: Disabled Veterans Recently Separated Veterans (within 3 years of discharge/release) Active Duty Wartime or Campaign Badge Veterans Armed Forces Service Medal Veterans Written Affirmative Action Plan (AAP) — required annually, outlining outreach and recruitment efforts, and including a hiring benchmark. Hiring & Promotion Benchmark — contractors must establish an annual hiring benchmark for protected veterans, either using the current national percentage published by OFCCP (updated annually — currently 5.1% as of 7/15/26) or a benchmark derived from their own data (relevant applicant/hiring pools, labor force data, etc.). Mandatory job listing with state workforce agencies — nearly all job openings must be listed with the appropriate state employment service delivery system (ESDS), giving veterans priority referral access. This is one of VEVRAA's most distinctive and frequently audited requirements — it's not optional or discretionary. Invitation to self-identify — contractors must invite applicants to self-identify as protected veterans at both the pre-offer and post-offer stages. Outreach and recruitment efforts — documented, ongoing outreach to veteran service organizations, transition assistance programs, and other veteran-focused recruitment sources — not a one-time effort, but tracked activity renewed each AAP cycle. Annual VETS-4212 report — covered contractors must file this annual report with the Department of Labor detailing veteran employment data, tied to the same $200,000 threshold and 50+ employee headcount. Recordkeeping — retention of applicant flow data, outreach records, and hiring benchmark data, typically for a minimum of 2 years, organized to withstand an OFCCP compliance evaluation. Subcontractor flow-down — covered contractors must include the VEVRAA equal opportunity clause in qualifying subcontracts, extending these obligations down the supply chain. Core Obligations Include:
OVERVIEW: SECTION 503 OF THE REHABILITATION ACT OF 1973Requires covered federal contractors to take affirmative action to employ, retain, and advance qualified individuals with disabilities. Basic nondiscrimination coverage: contractors/subcontractors with a federal contract of $20,000 or more (increased from $15,000, effective 10/1/25) Full AAP obligation: contractors with 50+ employees AND a contract of $50,000 or more Written Affirmative Action Plan (AAP) — updated annually, documenting outreach, recruitment, and internal analysis specific to individuals with disabilities. Utilization goal — 7% — OFCCP sets a nationwide 7% utilization benchmark (applied job- group by job-group, not company-wide) for individuals with disabilities. This is a goal for measuring progress, not a hiring quota — contractors who fall below it must document additional outreach efforts, not automatically hire to meet the number. Job group analysis — contractors with 100+ employees generally must organize jobs into job groups (similar content, wage rates, opportunities) to conduct utilization analysis against that 7% benchmark — refer to Section 503 job group design worksheet in the toolkit. Invitation to self-identify — applicants must be invited to self-identify as individuals with disabilities at the pre-offer stage, and again for employees periodically (every 5 years, with reminder in interim years), using DOL's standardized CC-305 form. *Note: keep using the current CC-305 even if its listed expiration date looks stale — OFCCP has confirmed it remains valid at this time. Outreach and recruitment efforts — documented, targeted outreach to recruitment sources serving people with disabilities (vocational rehabilitation agencies, disability-focused job boards, community organizations), reviewed annually for effectiveness. Reasonable accommodation procedures — a written process for employees/applicants to request accommodations, distinct from (but complementary to) ADA obligations. Audit and reporting system — internal tracking of hiring, promotion, and termination data by disability status, reviewed to catch problem areas (e.g., a job group with high turnover for employees who've self-identified). Anti-harassment/nondiscrimination policy statement — internal policy explicitly addressing disability nondiscrimination, typically included in the AAP itself and communicated to the workforce. Recordkeeping — retention of applicant flow data, self-ID data, and outreach records, generally 2 years minimum (1 year for contractors under 150 employees or under $150,000 in contracts), extended if a complaint or audit is pending. Subcontractor flow-down — the Section 503 equal opportunity clause must be included in covered subcontracts. Core Obligations Include:
RECOMMENDED RESOURCES PROTECTED VETERANS & INDIVIDUALS WITH DISABILITIES Direct Employers Association: DE will help post your jobs to many different Veteran friendly and vocational recruitment pages, offers an employer recruitment dashboard with very powerful analytics, external job postings to all required ESDS and more!. DE offers a monthly line-up of very informative webinars that are free and packed full of important information (keep up-to-date on EO’s, etc.) Contact: AJ Selvy aj@directemployers.org www.directemployers.org Click here to download DE’s VEVRAA Audit Readiness Checklist Buffer Springs – Veteran and Military Spouse Employment Consultants. This organization was founded and led by a disabled veteran, is a strong resource that is known for helping organizations put entire veteran recruitment strategies and programs into place, beginning with a consultation session that will dig deep into your current Veteran Recruitment program and offer creative strategies to boost veteran and military spouse recruitment and retention. Contact: Rob Ardnt, Founder rob@buffersprings.com www.buffersprings.com Click here to download BS’s Federal Contractor Tool Kit Complimentary Webinar “Alchemizing HR” https://zfrmz.com/FSBph9S73MezQyeR9J1I Recruit Rooster: RR is a subsidiary of Direct Employers, but focuses more on your talent marketing/branding through your website, apps, widgets, etc. They also have a really great technology tool that you can add to your website called “Military Crosswalk 2.0” which is essentially a translation tool that converts military occupation codes to find jobs within your company that match their skill set. Contact: Ruth Toombs ruth@recruitrooster.com www.recruitrooster.com How to enhance your Military Recruitment Efforts: https://vimeo.com/1095721826 VETS HIRED: Offers a variety of support options, especially including job unlimited job postings to Veteran Job boards, Virtual Job Fairs, Corporate Video Production, Direct Placement Services, etc. Contact: Oran Brown vets1@vetshired.us www.vetshired.us (Use Navigation links to view)
RECOMMENDED RESOURCES PROTECTED VETERANS & INDIVIDUALS WITH DISABILITIES Center for Disability Inclusion – Customized roadmaps tailored to your business objectives, integrating disability inclusion strategies that streamline operations, support accessible work environments, and ensure compliance with evolving regulations and best practices. We leverage data to help you stay ahead in a competitive landscape. Contact: Meaghan Walls mwalls@centerfordisabilityinclusion.org centerfordisabilityinclusion.org Skillbridge through DoD: An internship program where active military members who are ending their military assignments are transitioning into civilian workforce- you bring them into your organization and get paid by the government to do so for a period of time, with the expectation that once that time is up, you transition them into your payroll and offer them a career path. www.skillbridge.mil National Industry Liaison Group – lots of amazing resources for compliance, including very informative and free webinars. www.nationalilg.org Other Resources: Department of Veterans Affairs HiringourHeros.org Recruit Military JobsOhio.com Ohio Opportunities for Ohioans with Disabilities Job Accommodation Network EARN
RESOURCES FOR OFCCP COMPLIANCE AND AUDIT PREPAREDNESS This toolkit offers valuable resources to assist with OFCCP compliance and to ensure a successful OFCCP audit.YPHR Toolkit
YPHR Toolkit
CONTACT INFORMATION Meagan Perkins, SHRM-CP Need Assistance? We’re Here for You! Our Compliance Team is ready to help with any inquiries you may have, whether it’s about data collection, contract renewals, training opportunities, or vendor introductions. Don’t hesitate to reach out! 440-227-4930 Sonya Weiland, SHRM-CP, PHR sonya@yourpartnerinhr.com 216-860-2956 meagan@yourpartnerinhr.com Building Better Workplaces Together