A government form that sat inside nearly every federal contractor’s hiring packet for over a decade is now off-limits. As of September 21, 2026, the Department of Labor’s final rule modifying Section 503 of the Rehabilitation Act (91 FR 54482) is in effect, and federal contractors must stop asking job applicants and employees to self-identify their disability status using Form CC-305.
The rule also scraps the 7% disability utilization goal that contractors had been required to benchmark against since 2013, along with the related data collection and analysis obligations. The DOL’s rationale is that the old self-identification framework conflicts with the Americans with Disabilities Act, which generally restricts employers from making disability-related inquiries before a job offer.
What to do right now
If you hold a federal contract or subcontract, Form CC-305 needs to come out of your application workflows, onboarding packets, and any recurring employee surveys immediately. There is no grace period or phased rollout. As Duane Morris noted, the rule took effect 30 days after its August 21 publication with no transitional safe harbor.
That means HR teams, applicant tracking system vendors, and external recruiters all need to confirm the CC-305 fields are turned off in every active job requisition. Written affirmative action plans should also be updated to remove references to the utilization goal and disability data analytics.
What stays the same
Removing one form does not remove your broader obligations. Section 503’s ban on disability discrimination, its reasonable accommodation requirements, and the overall affirmative action plan mandate remain fully in place. Contractors with 50 or more employees and a contract of $50,000 or more must still document outreach efforts and maintain an audit and reporting system.
Veteran self-identification under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) is unaffected. And importantly, do not delete historical CC-305 data. Existing recordkeeping rules still apply, and that data could be needed for OFCCP audits covering prior compliance periods.
The separate change to Section 503’s contract coverage threshold, raised from $15,000 to $20,000, also took effect on September 21. Contractors near that line should review their contract portfolios to confirm which agreements still trigger affirmative action requirements.
A second effective date is worth marking on the calendar. The rule’s procedural changes to enforcement hearing rules under 41 CFR Part 60-30 do not kick in until December 2026, so contractors should track both deadlines through year-end.
