OFCCP Requests Comments on Proposed Elimination of Form CC-305

September 15, 2025

What's New

The Office of Federal Contract Compliance Programs (OFCCP) initiated a pre-clearance request for comments in preparation for the possible elimination of specified disability self-identification and data collection requirements under Section 503 of the Rehabilitation Act.

On July 1, 2025, OFCCP published a Notice of Proposed Rulemaking (NPRM) that, if approved, would remove requirements for federal contractors to: solicit their applicants’ and employees’ disability status; conduct a disability utilization analysis; and track disability applicant hire metrics used to assess Section 503 outreach.

OFCCP is soliciting comments on how the proposed revisions – including the proposed elimination of the agency’s Voluntary Self‐Identification of Disability Form (Form CC-305) – may affect the financial burdens associated with Section 503’s recordkeeping and reporting requirement.

What It Means

OFCCP will not formally seek the Office of Management and Budget’s approval of these changes unless and until a final rule is issued to eliminate the requirements described above. Meanwhile, all Section 503 compliance requirements remain intact. Interested parties have until October 24, 2025, to submit comments to OFCCP, which CWC intends to do.

What You Should Do

Federal contractors should continue to comply with Section 503 recordkeeping and reporting requirements. We encourage CWC members’ feedback on OFCCP’s proposals, which we will consider and incorporate as appropriate into CWC’s comments.

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Should Contractors Keep Using OFCCP’s Disability Self-ID Form If It Expires?

Apr 27, 2026 – OFCCP’s disability self-identification form is expiring on April 30, but federal contractors may continue using the form to comply with the self-ID requirements of Section 503’s regulations.

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May 14, 2026 – OFCCP has updated its Voluntary Self-Identification of Disability (Form CC-305) to a May 31, 2026 expiration date. Contractors may, at their discretion, update their forms or continue using the expired form until OMB formally approves an extension.

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