OMB Approves Section 503 Recordkeeping Requirements And Form CC-305

July 23, 2026

What's New

The White House Office of Management and Budget (OMB) approved and extended for an additional three years the Department of Labor’s (DOL) written affirmative action program requirements arising under Section 503 of the Rehabilitation Act. This includes DOL’s Voluntary Self-Identification of Disability Form (Form CC-305), with a new expiration date of July 31, 2029. Current DOL regulations require federal contractors to use Form CC-305 to invite applicants and employees to voluntarily report their disability status.

What It Means

OMB’s approval simply ensures that DOL’s Section 503 recordkeeping requirements remain in place while the Department continues to consider further refinement of its Section 503 regulations. Last summer the Department proposed eliminating the requirement that contractors “invite applicants and employees to self-identify their disability status,” along with the quantitative analytics that stem from tracking and tabulating these invitations. That proposal remains pending while the Department considers public comments on the proposal.

What You Should Do

Contractors should continue to comply with OFCCP’s disability self-identification regulations unless and until they are formally revised. Contractors should also update the expiration date of any electronic Form CC-305 to reflect July 31, 2029. A paper version, once available, will be updated on the Department’s Form CC-305 landing page.

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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.

OFCCP Updates Form CC-305 Expiration Date

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.

OFCCP Requests Comments on Proposed Elimination of Form CC-305

Sep 15, 2025 – OFCCP is soliciting comments on proposed revisions to an information collection request but will seek OMB approval only if a final rule is issued eliminating many longstanding disability compliance requirements.

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Mar 22, 2023 – In conjunction with the 30th anniversary of the federal Family and Medical Leave Act, we’ve updated CWC’s popular FMLA Compliance Outline, a comprehensive resource designed to assist our members in understanding the FMLA’s basic requirements.

OMB Approves Section 503 Recordkeeping Requirements And Form CC-305

Jul 23, 2026 – OMB has approved the Voluntary Self-Identification of Disability Form (Form CC-305) through July 31, 2029, while OFCCP continues to consider whether to retain disability self-ID requirements.

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