CWC Recommends OFCCP Retain Form CC-305 On A Voluntary Basis

October 30, 2025

What's New

CWC has filed comments with the Office of Federal Contract Compliance Programs (OFCCP) in response to its proposal to eliminate Form CC-305, through which federal contractors solicit applicants’ and employees’ disability status.

OFCCP’s Form CC-305 proposal follows a related proposal to eliminate the requirement for contractors to “invite applicants and employees to self-identify their disability status,” along with the quantitative analytics that stem from tracking and tabulating these invitations.

CWC’s comments urge OFCCP to retain Form CC-305 as a permissible – but not mandatory – method of soliciting disability status to support federal contractors’ Section 503 compliance programs. Our comments note that while Form CC-305 is an imperfect tool, CWC members collectively have invested millions of dollars in time and resources implementing and maintaining Form CC-305. We asserted that Form CC-305 should remain a viable option for those contractors that intend to continue soliciting employee disability status.

What It Means

OFCCP will not formally seek approval from the Office of Management and Budget for these changes unless and until it decides to issue a final rule eliminating the requirements described above. In the meantime, all Section 503 compliance requirements remain intact.

What You Should Do

Federal contractors should continue to comply with Section 503 recordkeeping and reporting requirements, including the use of Form CC-305. Contractors frequently ask whether they should pause any upcoming disability surveys of the workforce in light of the proposed changes. We see no need to reschedule these surveys unless and until OFCCP eliminates this requirement.

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CWC Recommends OFCCP Retain Form CC-305 On A Voluntary Basis

Oct 30, 2025 – CWC has filed comments with OFCCP urging it to consider alternatives to its proposed elimination of the Voluntary Self-Identification of Disability Form (Form CC-305).

CWC Urges OFCCP To Consider Alternatives To Section 503 Rulemaking

Sep 25, 2025 – CWC has filed comments with OFCCP urging it to consider alternatives to its proposed revisions of nondiscrimination and affirmative action regulations under Section 503 of the Rehabilitation Act.

OMB Approves OFCCP’s Revised Disability Self-ID Form CC-305

May 1, 2023 – OMB has approved OFCCP’s request to continue mandating a slightly improved but still highly prescriptive version of the Disability Self-ID Form CC-305 for another three years.

Multiple Foreign Language Versions Of OFCCP’s CC-305 Disability Self-ID Form Now Available

Jun 28, 2023 – OFCCP has translated its prescribed disability self-ID form (CC-305) into several different foreign languages.

CWC Comments Urge Changes To OFCCP’s Disability Self-ID Form CC-305

Apr 26, 2023 – CWC has filed comments with OMB urging that agency to mandate sensible changes to OFCCP’s overly prescriptive Form CC-305 before giving OFCCP clearance to continue using the form for another three years.

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