OFCCP Resumes Section 503 and VEVRAA Enforcement

3:38

By Zach Olsen

On July 2, 2025, U.S. Secretary of Labor Lori Chavez-DeRemer issued Order 08-2025, which allows the Office of Federal Contract Compliance Programs (OFCCP) to resume its enforcement activities related to Section 503 of the Rehabilitation Act (Section 503) and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). This follows an earlier order by then-Acting Labor Secretary Vincent N Micone, III, which temporarily halted all OFCCP enforcement activity after Executive Order 11246 was revoked by Executive Order 14173.

What the Order Says

Section 503 and VEVRAA enforcement can now resume, particularly related to investigating complaints
- This includes the investigation of complaints filed while this enforcement activity was held in abeyance
- Based on the title of the order, it appears that Section 503 and VEVRAA enforcement for open compliance reviews could continue
All Pending Compliance Reviews to Close
- Pending compliance reviews from the November 2024 scheduling list will be administratively closed
  - The agency said this is due to the previous 503/VEVRAA review format being “significantly entangled” with previous Executive Order 11246 enforcement.
- It is unclear from whether conciliation agreements for Section 503/VEVRAA violations will be closed
- Impacted contractors will promptly receive notification from the agency of these administrative closures
OFCCP Certification Period Remains Closed
- Covered contractors should note that compliance with Section 503 and VEVRAA regulations should continue, but the certification period will remain closed at this time
Veteran Affairs Health Benefits Program (VAHBP) Moratorium Extended
- Enforcement for VAHBP providers remains paused through May 7, 2027

Takeaways for Federal Contractors

For federal contractors, the pace and inconsistency of recent OFCCP developments may feel a little bit like whiplash. This order comes just weeks after the Trump administration’s FY26 budget proposal revealed plans to close OFCCP. Conversely, the agency has now resumed enforcement under Section 503 and VEVRAA, signaled its continued activity through new proposed regulatory changes, and issued voluntary information requests from federal contractors.

Despite the confusion, this much is clear:

OFCCP has been consistent in stating that Section 503 and VEVRAA regulations are still in full force and effect, including the requirements to annually develop AAPs
OFCCP appears it will remain active despite the proposed broader structural changes to agency operations and the enforcement of Section 503 and VEVRAA
Contractors should continue to meet their obligations under Section 503 and VEVRAA and be ready to defend their employment practices in any remaining open audits and/or complaint investigations

DCI will continue to monitor this ongoing situation and provide insight as it becomes available.