Federal Contractor Compliance After the 2026 Rule Changes
Section 503 and VEVRAA still apply. EO 11246 requirements are ending. We handle both, plus the pay equity analysis underneath them.
Trusted Clients
Two risks now: keeping programs you no longer need, and dropping ones you still have to run.
Effective October 26, 2026, the EO 11246 regulations are rescinded. Race and sex-based affirmative action plan requirements end with them. Obligations for individuals with disabilities and protected veterans continue unchanged.
What still applies to you
Section 503 and VEVRAA programs
We build and maintain separate written programs for individuals with disabilities and for protected veterans. Each includes:
Policy statement signed by leadership
Review of personnel processes
Physical and mental job qualification review
Reasonable accommodation procedures
Harassment prevention procedures
Outreach and recruitment, with documented effectiveness assessment
Self-identification invitations in the required formats, pre-offer and post-offer
Applicant and hire data collection by disability and veteran status
Utilization measured against the 7% goal, and veteran hiring against the annual OFCCP benchmark
Internal audit and reporting
Training for recruiters, hiring managers, and supervisors
Recordkeeping for the required retention period
The analysis underneath
Compliance documents are only as good as the numbers behind them. We run four analyses, all at the job group or job family level so the results are comparable and defensible.
Adverse impact.
We test hiring, promotion, and termination decisions for disparities by gender and race or ethnicity. We use the four-fifths rule as a practical flag and standard deviation analysis to test whether a disparity is likely to be chance.
Utilization versus availability.
We compare your workforce composition to the labor market you actually recruit from, by job group and geography.
Pay equity.
Comparative pay analysis by gender and race or ethnicity within job groups. Regression analysis where sample sizes support it, controlling for tenure, performance, and qualifications. Mean and median comparisons where they don't.
Job group structure.
If the groups are wrong, every analysis built on them is wrong. We review the structure before running anything.
Working under privilege
Pay equity and adverse impact findings can be discoverable. Where your exposure is real, we work at the direction of your counsel so the analysis is covered by attorney-client privilege.
We do this routinely. Raise it with your lawyer before we start, not after we find something.
Training
Compliance documents don't change behavior. We train HR, hiring managers, and leadership on what the rules now require, how the analyses work, and how to run selection and pay decisions that hold up.
Why us
Our founder began his career with the U.S. Department of Labor. We have been writing and defending these programs for 30 years, in English and Spanish, for employers with operations in the mainland US and Puerto Rico.
Questions, Answered.
Section 503, VEVRAA, and pay equity work for federal contractors and subcontractors, nationwide, in English and Spanish.