Disability Self-ID Form Expiration Date Approaching: What Federal Contractors Need to Know
By Macy Cheeks and Victoria Ungvary
BLOG OVERVIEW: OFCCP's Voluntary Self-Identification of Disability Form (CC-305) is set to expire on April 30, 2026. Under the Paperwork Reduction Act, federal agencies must seek OMB approval every three years to continue using an information collection, and the form may lapse before renewal is finalized. Until OFCCP issues further guidance or a final rule is published, contractors should continue using the current CC-305 form to demonstrate good-faith compliance with existing regulations.
Federal contractors are required to invite applicants and employees to voluntarily self-identify their disability status using the Office of Management and Budget (OMB)-approved Voluntary Self-Identification of Disability Form CC-305. This form will expire on April 30, 2026; however, we have yet to see a final notice from the Office of Federal Contract Compliance Programs (OFCCP) regarding its renewal. The lack of guidance from the agency creates uncertainty for federal contractors and may also signal the broader fate of disability data collection moving forward.
Information Collection Renewals Under the Paperwork Reduction Act
Under the Paperwork Reduction Act (PRA) (44 U.S.C. § 3512), federal agencies must seek renewal with OMB every three years to continue using an information collection regardless of whether changes are being made. The renewal is similar to the approval process for a new form and includes publishing a 60-day and 30-day notice in the Federal Register, along with an OMB review of supporting documentation.
In late August 2025, OFCCP published the 60-day notice in the Federal Register referencing the July Notice of Proposed Rule Making (NPRM) that would remove the disability self‑identification requirement, among other changes. The notice asked for comments focused on:
- Whether the collection of the information is necessary for OFCCP’s functions;
- Evaluating the accuracy of the burden estimate associated with the form and data collection;
- Suggestions for ways to enhance the quality, utility, and clarity of the information collected; and
- Ways to minimize the burden of collecting information from respondents.
The public comment period ended on October 24, 2025. There has been no 30-day notice published yet as we continue to get closer to the form’s expiration date. This would not be the first time an OMB-approved information collection request (ICR) expires before a renewal is finalized. Typically, if the renewal of an ICR is still being reviewed, OMB allows the existing information collection to continue in month-to-month increments. In 2020, for example, the revisions to the Voluntary Self-Identification of Disability Form were not submitted to OMB until the expiration date of the then-current form. Because the renewal was submitted before the approval lapsed, the collection was permitted to continue during OMB’s review, allowing contractors to use the existing form for more than three months before final approval of the renewal was issued.
Compliance Considerations if CC-305 Expires
A lapse in the form’s OMB approval does not eliminate the underlying regulatory obligations imposed by Section 503 of the Rehabilitation Act (Section 503). The regulations at 41 C.F.R. § 60‑741.42 require federal contractors to invite applicants and employees to self‑identify their disability status using the “prescribed form” provided by OFCCP. As mentioned, OFCCP’s proposed changes to the Section 503 regulations include the elimination of the self-id form and would remove the disability self‑identification requirement altogether. However, a decision on the final Section 503 rulemaking has not yet been completed; in the interim, the regulatory obligation remains in effect, and Form CC-305 remains the “prescribed form” for collecting the self-identification information.
Barring any updated guidance from OFCCP, DCI recommends that contractors continue using the existing Form CC-305 until more information is available or a final rule is published. Continuing the current practice demonstrates a good‑faith effort to comply with existing regulatory requirements and helps avoid disruptions in the data necessary to perform annual analyses, while the current Section 503 regulations remain in effect.
DCI will continue to monitor the Federal Register for any notices published regarding the renewal of the disability self-identification form.
