By Mitchell Chamberlin and Joanna Colosimo
BLOG OVERVIEW: OFCCP has released new minimum contract thresholds for federal contractors and subcontractors. These thresholds help determine whether employers must adhere to requirements stemming from Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act.
On November 25, 2025, the Office of Federal Contract Compliance Programs (OFCCP) published updated contract thresholds for federal contractors and subcontractors. These thresholds were updated by the Federal Acquisition Regulation (FAR) Council, which is required by Section 807 of the Ronald Regan National Defense Authorization Act to review dollar threshold amounts for certain federal agency procurement-related laws every five years.
DCI covered these changes when they were proposed, along with FAR’s methodology for calculating increases, in a previous blog.
New Minimum Contract Amounts of VEVRAA and Section 503 Compliance
The new thresholds determine whether federal contractors and subcontractors must comply with the regulations Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) and Section 503 of the Rehabilitation Act (Section 503), and if so, to what degree. The specific thresholds are below:
Section 503
|
Coverage Level |
Number of Employees |
Updated Minimum Contract Amount |
|
Basic Coverage |
Any Number of Employees |
$20,000 or More |
|
AAP Coverage |
50 or More Employees |
$50,000 or More |
VEVRAA
|
Coverage Level |
Number of Employees |
Updated Minimum Contract Amount |
|
Basic Coverage |
Any Number of Employees |
$200,000 or More |
|
AAP Coverage |
50 or More Employees |
$200,000 or More |
Organizations that meet the Basic Coverage threshold must adhere to the foundational non-discrimination and affirmative action requirements such as not discriminating on the basis of disability or protected veteran status and posting specific equal employment opportunity (EEO) taglines in job postings. Those that meet the AAP Coverage threshold have additional compliance requirements, such as developing affirmative action programs and listing open positions with employment service delivery systems, which is a requirement stemming from the VEVRAA regulations.
Signs of Life at OFCCP
Since President Trump signed Executive Order 14173, the future of OFCCP has been in question. However, the release of these new jurisdictional thresholds may be another sign that OFCCP will continue to enforce affirmative action and equal employment opportunity requirements for employers with federal contracts or subcontracts under Section 503 and VEVRAA.
DCI will continue to monitor OFCCP’s activities and release additional information when needed.
