BLOG OVERVIEW: A September 2026 GAO report (GAO-26-107937), released October 6, finds that reduced oversight, deep staffing cuts, and withdrawn guidance have weakened Section 503 compliance enforcement. GAO issued eight recommendations, including that OFCCP resume compliance audits and annual AAP certification through the Contractor Portal, both suspended since January 2025. DOL neither agreed nor disagreed with those two but agreed to analyze complaint closures, plan its workforce, and publish new recruitment, accommodation, outreach, and best practice resources for contractors. Federal contractors should keep Section 503 programs current as GAO continues monitoring DOL’s progress.
On October 6, 2026, the Government Accountability Office (GAO) released a report examining how the Department of Labor (DOL) and its Office of Federal Contract Compliance Programs (OFCCP) oversee compliance with Section 503 of the Rehabilitation Act (Section 503). The report, Disability Employment: DOL Should Enhance Monitoring and Guidance for Federal Contractors, provides a look into the current state of OFCCP and outlines eight recommendations to improve Section 503 oversight and contractor compliance. Most notably, GAO recommends resuming compliance audits and annual affirmative action plan (AAP) certification, two activities that have been suspended since January 2025.
GAO conducted the review at the request of Senators Bernie Sanders and Kirsten Gillibrand to examine OFCCP’s implementation and oversight of Section 503. Findings indicate that DOL’s reduced oversight, poor workforce planning, and withdrawal of regulatory guidance have weakened Section 503 enforcement and created confusion within the contractor community on current regulatory requirements and best practices. GAO’s report issued eight recommendations addressing ongoing challenges:
GAO’s first two recommendations address the impact of OFCCP pausing two foundational Section 503 monitoring activities: proactive compliance audits and annual AAP certification through the Contractor Portal. OFCCP’s compliance audits have long served as a key monitoring tool for assessing federal contractors’ compliance.
In recent years, OFCCP began conducting focused reviews, specifically examining compliance with Section 503. GAO notes that in 2020, OFCCP issued a report highlighting the benefits of these focused reviews, concluding that they resulted in greater attention to increasing employment opportunities for individuals with disabilities. Contractors also appeared to benefit from the targeted technical assistance received during focused reviews, according to the report.
GAO argues that without audits, DOL cannot reasonably ensure that contractors are meeting their obligations to support the employment of individuals with disabilities and recommends resuming Section 503 compliance reviews. While DOL neither agreed nor disagreed with the recommendation, DOL noted that it continues to enforce Section 503 through complaint investigations.
In 2016, GAO released a report encouraging OFCCP to develop a monitoring system to help efficiently identify federal contractors that were at risk of noncompliance. As a result, in 2022 OFCCP began requiring covered organizations to certify compliance on an annual basis in a new Contractor Portal. However, after the rescission of Executive Order 11246 (EO 11246), OFCCP closed the Portal.
In its most recent report, GAO recommends that OFCCP resume collecting AAP certifications to provide greater assurance that contractors are complying with the requirement to have AAPs, and to clarify which compliance obligations remain in effect amid regulatory changes.
DOL acknowledged the ongoing regulatory changes and indicated that it has no plans to resume certifications at this time. While OFCCP’s plans for the Contractor Portal remain uncertain, it could serve as an efficient way to reinstate some level of annual contractor oversight.
What this means for contractors: The possibility of audits and annual AAP certification should not be ruled out. GAO’s research and subsequent report strongly affirm the value of compliance audits and AAP certification as effective Section 503 enforcement methods.
GAO’s report also highlights concern about inefficiencies in the complaint process—the one area where the agency remains active—and about the lasting effects of OFCCP’s recent reorganization.
GAO found that between fiscal years 2021 and 2025, OFCCP investigated about 3% of the Section 503 complaints it received. The other 97% were either closed without investigation (for example, the complainant withdrew the complaint or settled with their employer) or referred to other agencies, such as the Equal Employment Opportunity Commission (EEOC). GAO observed that while OFCCP tracks complaint outcomes, it does not analyze the data to better manage the complaint procedure, which is inconsistent with federal standards for internal control.
GAO also notes that, beginning in 2025, DOL began reorganizing OFCCP, resulting in a workforce drop from 484 to 79 full-time employees, and from 50 field offices to 6. The report recommended that further changes in OFCCP’s workforce should be strategic and must align with both the agency’s current responsibilities and future needs.
OFCCP agreed with both recommendations and committed to engaging in analysis of complaint investigation trends, as well as action plans to close gaps in strategic workforce planning.
What this means for contractors: As noted earlier, GAO reports have prompted OFCCP changes in the past. In response to GAO’s findings, Director Kenneth Wolfe has committed to improving the agency’s strategic operations. In addition to maintaining Section 503 compliance programs, contractors should monitor DCI’s resources for news and analysis of OFCCP workforce changes, which may signal if and when additional enforcement activity will resume.
Additionally, GAO found that contractors have been left to navigate Section 503 compliance with limited federal guidance and little clarity into how their efforts may be measured or evaluated in the future. Four of GAO’s eight recommendations addressed gaps in guidance, communication, and support for contractors. In response, DOL agreed with the assessment and confirmed that OFCCP is working on additional resources to address GAO's recommendations.
For Fiscal Year 2027, DOL agreed to several actions aimed at helping contractors better understand and meet their Section 503 obligations, including:
What this means for contractors: Contractors should plan to leverage these resources as they become available to support their ongoing Section 503 compliance efforts.
AAP obligations have been reshaped by political headwinds in recent years. But GAO’s report, driven by congressional concern, indicates a refocus on Section 503 enforcement is likely to come – regardless of whether it is before or after a political shift.
While the GAO investigation was specific to Section 503 enforcement, scrutiny of federal contractor obligations extends beyond disability compliance. As DCI recently discussed, a RAND study shared with the White House raised concerns about how companies support veteran employment and highlighted gaps in veteran hiring, retention and advancement data.
Taken together, these reports signal growing attention to OFCCP’s oversight responsibilities. The pressure is now on DOL to demonstrate progress not only in resuming enforcement activities, but also in providing contractors with the guidance and resources needed to comply. While the timing and extent of future enforcement remain uncertain, GAO has indicated that it will continue monitoring DOL’s progress in implementing its eight recommendations.
Finally, the report also highlights challenges contractors have faced in recent years, including the difficulty of demonstrating compliance, and, at times, even understanding what is required to remain compliant. DCI's Section 503 services can help contractors maintain accurate, up-to-date documentation and prepare for investigations or potential future oversight.
DCI will continue tracking developments and sharing updates as additional guidance becomes available.