What RAND's VETS-4212 Findings Mean for Federal Contractors

BLOG OVERVIEW: RAND published a 66-page analysis on September 9, 2026 examining how S&P 500 companies support veterans across four public data streams: SEC 10-K filings, voluntary communications, corporate foundation grantmaking, and VETS-4212 reports. S&P 500 federal contractors hired protected veterans at 2.4% of new hires in 2025, well below the 5.1% VEVRAA benchmark, though that figure deserves an asterisk because RAND excluded every non-headquarters establishment. RAND also found that veteran-related grants make up under 1% of S&P 500 foundation giving and that 2025 DEI rollbacks appear to have affected veteran programs, and it recommends that Congress, DOL, and SEC significantly expand veteran workforce reporting. 

On September 9, 2026, RAND, a nonprofit, nonpartisan research organization, published a 66-page analysis of how S&P 500 companies support veterans. This research evaluated four main data streams: Securities and Exchange Commission (SEC) 10-K filings, voluntary communications, corporate foundation 990-PF grantmaking, and VETS-4212 federal contractor and subcontractor reports.

The report landed the same week a White House Executive Order focused on veteran employment opportunities was published and provides specific recommendations to Congress, the Department of Labor, and the SEC regarding the tracking of veterans in the workforce. Given the high-profile nature of the recipients of the recommendations, in alignment with the White House Executive Order, federal contractors should be preparing for potential adoption of some of the recommendations from this report.

Report Findings

The report found that most employers described veteran outreach initiatives extensively in voluntary communications but rarely documented them in the mandatory SEC 10-K filings. Furthermore, it found that veteran-related grants are under 1% of observed S&P 500 foundation giving levels, with the veteran share of total corporate giving falling from .88% to .57% over the study window.

Of importance, the study examined VETS-4212 filing data from 2021-2025 and hiring benchmark standards from the Office of Federal Contract Compliance Programs (OFCCP). The report noted that “VETS-4212 data provide useful snapshots of protected veteran hiring and employment, but they do not track what happens after the initial hire.” In other words, federal contractor data measures entry into the workforce far better than the quality or longevity of veteran civilian careers.

Additionally, the report analyzed 2025 VETS-4212 data from federal contractors that are in the S&P 500 and found that veteran hiring at these employers was at 2.4% of total hiring, which is well below the 5.1% hiring benchmark that took effect in July 2025 (and has not been updated for federal contractors by the publishing of this blog).

Finally, the report indicated that broader DEI initiatives that were cut in 2025 may have had a spillover effect, negatively impacting veteran programs as well. Using case studies, the report found that some firms, not surprisingly, housed veteran initiatives alongside other DEI-related programs.

The 2.4% Finding Deserves a Major Asterisk

In reviewing the methodology from the report and the 2.4% finding from VETS-4212 hiring data, there are some assumptions and limitations that must be noted. First, RAND retained only Single Establishment and Multiple Establishment – Headquarters reports to avoid “double counting”. In doing so, however, RAND excluded every non-headquarters location of multi-establishment contractors.

Additionally, RAND’s own occupational breakdown shows craft workers and technicians above the 5% protected veteran hiring share, while administrative support and service workers sit between 2% and 3%. The methodology to filter out all non-HQ establishments would result in an exclusion of plants, field operations, distribution centers and other locations where veterans are likely concentrated given the craft worker and technician representation, potentially skewing the overall veteran hiring number down.

Report Recommendations

The RAND report made several recommendations based on its findings.

• Issue federal guidance clarifying that veteran hiring and support programs remain lawful and distinct from “DEI restrictions.”

• Congress and the Department of Labor should consider updating VETS-4212 reporting for large contractors to include category-specific counts of protected veteran employees and new hires, along with 12- and 24-month retention, promotion rates, and management representation.

• Publish large-contractor veteran employment outcomes in a centralized database searchable by different variables such as company, parent firm, industry, contract size, and filing year.

• Require a light-touch Form 10-K human-capital disclosure table for publicly traded federal contractors above a contract threshold. The table should report metrics such as veteran hires, workforce representation, management representation, and year-over-year retention.

• Adopt a standardized procurement disclosure requiring large defense contractors to report on veteran hiring, retention, advancement, military-related philanthropy, volunteer activity, and CEO or board oversight — the report found little systematic relationship between military contract exposure and observable veteran support.

• Develop a standardized voluntary reporting template for veteran-related corporate giving, since public tax data captures only grants made through identifiable corporate foundations.

• For companies, build veteran employment programs with dedicated staff, senior support, and measurable goals.

Next Steps for Contractors

With recommendations going to Congress, the Department of Labor, and SEC, contractors should consider voluntarily adopting some of the recommendations proactively as a part of their Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) programs. Below are some practical considerations.

• Audit veteran self-identification data. Check pre- and post-offer invitation mechanics to ensure timing and messaging are clear. Given the findings on the low hiring numbers overall, it is an opportunity for contractors to validate their veteran data collection, regardless of the report’s limitations.

• Document your veteran hiring benchmark comparison and veteran outreach effectiveness as a part of your VEVRAA affirmative action program.

• Review your veteran hiring benchmark across enterprise and establishments. RAND’s HQ-only 2.4% figure isn’t your company’s figure. Take the extra step to understand your organization’s data across the enterprise and by establishment.

• Consider tracking retention, promotion, and management representation by veteran status. This is aligned with RAND’s recommendations for improved VETS-4212 reporting and is something most contractors do not currently measure. If you are a DCI client, please contact your consultant for more information.

• Consider how your veteran programs are structured. In alignment with the observation that some veteran programs were eliminated alongside DEI programs, understand and evaluate how your organization is supporting veteran applicants, new hires, and employees throughout the employment lifecycle.

• Reconcile your VETS-4212 filings against your VEVRAA affirmative action plan data. If a database becomes public with these figures, according to the RAND report recommendations, a comparison against peer companies in your industry may be easy to do, and you should be prepared.

Where This Goes Next

RAND itself acknowledges that its findings reflect the limits of the public record and do not assess any one company’s actual veteran programs. However, it hands Congress a specific, potentially low-burden reporting request. Contractors who build veteran retention and advancement tracking in the next 12-18 months should be prepared for potential future changes.

DCI will continue tracking developments regarding required data collection and submission for federal contractors and employers.