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Updated November 25, 2025

If your business holds federal contracts, now is the time for you to review OFCCP's new jurisdictional thresholds for Section 503 and VEVRAA that went into effect on October 1, 2025. The new threshold requirements are listed below for Section 503 and VEVRAA. 

New Jurisdictional Thresholds & AAP Requirements

Section 503: The basic coverage threshold rose from $15,000 to $20,000. AAP requirements continue for contractors and subcontractors with at least 50 employees and a single contract of $50,000 or more.​

VEVRAA: The threshold increased from $150,000 to $200,000. AAP requirements apply to contractors and subcontractors with at least 50 employees and a single federal contract of $200,000 or more.

Do you know what Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) mean for your organization? These two regulations are key to ensuring fair hiring practices and fostering inclusive workplaces, especially when it comes to IWD and protected veterans. If you're curious as to how these laws might impact your compliance strategy, read on! 

Updated November 25, 2025

If your business holds federal contracts, now is the time for you to review OFCCP's new jurisdictional thresholds for Section 503 and VEVRAA that went into effect on October 1, 2025. The new threshold requirements are listed below for Section 503 and VEVRAA. 

New Jurisdictional Thresholds & AAP Requirements

Section 503: The basic coverage threshold rose from $15,000 to $20,000. AAP requirements continue for contractors and subcontractors with at least 50 employees and a single contract of $50,000 or more.​

VEVRAA: The threshold increased from $150,000 to $200,000. AAP requirements apply to contractors and subcontractors with at least 50 employees and a single federal contract of $200,000 or more.

Although compliance may not be the most exciting part of HR management, it’s still one of the most important, especially if you're a federal contractor. With some of the recent regulatory changes, including the January 2025 rescission of Executive Order 11246, you may be wondering where that leaves your obligations under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA). 

Federal contractors and subcontractors have long been required to conduct annual pay equity reviews under under Executive Order 11246. This process identifies and corrects pay disparities based on race, gender, or ethnicity. Although EO 11246 has been rescinded the value of conducting them still remains as critical as ever. 

OutSolve has invited John C. Fox, Esq. as a guest blogger providing legal insights on EEO and compliance issues. The views expressed in his posts are his and do not reflect the viewpoint of OutSolve or its employees.

In John Fox's last blog, he explored the legal risks under the False Claims Act (FCA) when certifying compliance on federal contracts and grants, highlighting the need for proactive evaluation and internal review. In this follow-up blog, Fox explains how two major federal agencies, the DoD and GSA, are already implementing binding contract changes in response to the new anti-DEI Executive Orders. While formal FAR Council rules are still pending, these Class Deviations make one thing clear: change is happening now and contractors must be ready.

FEDERAL CONTRACT/GRANT CLAUSES UPDATE: The Federal Acquisition Regulatory (FAR) Council has yet to issue Proposed, let alone Final, Rules to implement throughout the federal government the two anti-DEI certifications President Trump has ordered up. The Council also has NOT forecast a publication date. (They are a bit busy in Washington D.C. at this time.) 

OutSolve has invited John C. Fox, Esq. as a guest blogger providing legal insights on EEO and compliance issues. The views expressed in his posts are his and do not reflect the viewpoint of OutSolve or its employees.

On April 15, 2025, ten former senior officials from the U.S. Department of Labor (DOL), including past leaders of the Office of Federal Contract Compliance Programs (OFCCP) and former Solicitors of Labor, released an open letter to federal contractors. This letter addresses the recent rescission of Executive Order (EO) 11246 by President Trump and the subsequent issuance of EO 14173, titled "Ending Illegal Discrimination and Restoring Merit-Based Opportunity." 

April is here and with that comes the end of the 90-day safe harbor period for federal contractors complying with EO 11246. As April 21, 2025, approaches, federal contractors are obligated to transition away from EO 11246 requirements, or affirmative action plans (AAP) for women and minorities to EO 14173. 

OutSolve has invited John C. Fox, Esq. as a guest blogger providing legal insights on EEO and compliance issues. The views expressed in his posts are his and do not reflect the viewpoint of OutSolve or its employees.

OutSolve has invited John C. Fox, Esq. as a guest blogger providing legal insights on EEO and compliance issues. The views expressed in his posts are his and do not reflect the viewpoint of OutSolve or its employees.

The U.S. Department of Labor (DOL) announced their new Director of the Office of Federal Contract Compliance Programs (OFCCP) on March 24, 2025. Catherine Eschbach will now lead the department in its transition from EO 11246 to EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity. Eschbach is quoted as saying she will work to “restore a merit-based system to provide all workers with equal opportunity.”