Section 503 Compliance: Key Considerations for Employers

As a former practitioner turned consultant, I have spent many years in your shoes, from managing EEO obligations to inclusion program management focused on veterans and individuals with disabilities and hundreds of OFCCP audits during my career. One area that has always been particularly partial to me is disability inclusion, and an area where I served as the subject matter expert in my over 25 years of HR compliance roles. I view compliance as the baseline to build upon, and the foundation for efforts moving forward, and whether you’re working on veteran programs or disability programs, the same fact rings true! Let’s dive into Section 503 and what I’ve found to be helpful starting points for companies of all sizes.

Overview of Section 503 & Its Relationship to Americans with Disabilities Act (ADA)

I view Section 503 compliance as an enhanced extension of the Americans with Disabilities Act (ADA). While Section 503 is specifically geared toward organizations with government contracts of $20,000 or more, its provisions offer significant guidance that is applicable to employers seeking greater inclusion of individuals with disabilities.

Audit & Review Process

Section 503 regulations require certain activities, which have historically been audited by the Office of Federal Contract Compliance Programs (OFCCP). Although Section 503 Focused Reviews previously occurred, a limited number of federal contractors experienced these specific audits. However, for those who had OFCCP compliance evaluations, a portion of the audit was focused on Section 503 compliance as part of an affirmative action review. Fast-forward to 2025/2026, while no compliance evaluations have been issued, the obligations of Section 503 still remain firmly in place.

Disability Inclusion & Benchmarking

Beyond government audits, many organizations have participated in benchmarking efforts. These include completing the Disability Inclusion Blueprint managed by the National Organization on Disability (NOD) and the Disability Index managed by Disability:IN, formerly known as the United States Business Leadership Network (USBLN). Additionally, Fair360, formerly known as Diversity Inc, places emphasis on disability inclusion benchmarking as a portion of their top employer listings for many years. These benchmarks allow organizations to monitor their disability inclusion efforts and improve employment outcomes by comparing data from 150+ others across various industries.

Changes in Practice & the Importance of Review

Over the past year, many disability benchmarking practices have been discontinued or paused for the time being. Several of these initiatives were valuable, offering benchmarking data and recommended best practices for federal contractors subject to Section 503 requirements. To be clear, the revocation of Executive Order 11246, directly affecting affirmative action for women and minorities, did not remove the affirmative action requirements for Section 503 of the Rehabilitation Act or the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) as amended. Those efforts should still be ongoing without a lapse in efforts.

Recommendations for Employers

Amidst the changing landscape, employers should pause to review their past compliance efforts in the disability compliance space, and consider how to maintain and/or strengthen their commitment to disability inclusion moving forward, prior to OFCCP establishing revised compliance review protocols. Consider an internal review of your Section 503 compliance.

Experience Managing Diversity Disability Inclusion & Section 503 Compliance

Over the years, I have managed diversity and disability inclusion programs and overseen Section 503 compliance efforts, while also participating in more than 100 audits throughout the process. This experience provided valuable insights and practical tips that proved effective in not only achieving Section 503 compliance but also assisting with integrating disability inclusion as a key component of the organization’s broader inclusion strategies. The following actionable efforts and recommendations I found to be particularly useful throughout my career, and I encourage you to consider adapting or adopting them to strengthen your own organization’s approach to disability inclusion.

Maintain Confidential Handling of Disability Self-ID (Form CC-305) Data

Use Self-ID information for government reporting purposes only. Limit access to individuals supporting Section 503 compliance and those with a strict need-to-know basis, and clearly communicate that Self-ID is not the same as disability disclosure. Where appropriate, analyze progress toward the 7% utilization goal company-wide and ensure the required re-survey/invitation cadence is maintained. If you still maintain job groups, you may continue to monitor and review the percentage in that manner. The requirement is to conduct a re-survey every five years. Organizations that are disability friendly over the years have conducted large corporate campaigns to encourage self-ID. I’m a believer and many have confirmed that it’s best not to conduct a disability self-ID campaign aligned with open enrollment, which may discourage self-ID with the assumption the data may be used to increase benefit costs in the future. Consider combining your campaign with the collection of other data you may need, like veteran status. Based on the revocation of Executive Order 11246 I would suggest not including race and gender surveys. Although the current CC305 used to collect self identification information for individuals with disabilities is expired, in the past the OFCCP allowed federal contractors to utilize it until renewed. It’s anticipated that the form will be renewed by OMB once again so watch closely to ensure once approved you are using the updated form.

Establish End-to-End Accommodation Support Across the Employee Lifecycle

Take effort to ensure the accommodation process is communicated throughout the organization to include the applicant phase, onboarding, and ongoing employment. Conduct periodic reviews of accommodations requested, granted, and denied; ensure managers understand when the interactive process is triggered; and provide annual training. Make sure your HR team and managers are familiar with the process and know who to contact when they have questions.

Engage with Disability-Focused Employee Resource Groups (ERGs) with Appropriate Governance

If your organization has a disability-focused employee resource group (ERG) or business resource group (BRG), try to engage with them and join as a member. When a discussion among the group has compliance implications, and it will, you can address them along the way and assist early to ensure items requiring further discussion or review are mapped to an appropriate HR member or legal, as needed. These groups should be cautioned not to use their forum to bypass established HR policies or practices, and should make it clear that they are open to all employees, regardless of disability status.

Provide Disability Etiquette Training

Offer training that builds practical understanding of disabilities for employees and co-workers, leveraging credible resources and emphasizing that disabilities vary; reinforce respectful practices to reduce risk of complaints. Use learning in the disability space to increase inclusion!

Build Partnerships with National & Local Disability Organizations

Attend disability-focused conferences and webinars and subscribe to receive the Office of Disability Employment Policy (ODEP) alerts. ODEP is an agency within the Department of Labor, however they are not an enforcement agency. They are an agency that provides a plethora of information focused on individuals with disabilities, as well as disability policies, and practices. Combined with ODEP, you may also leverage another disability-focused partner resource, the Job Accommodation Network (JAN). Both will assist you in understanding multiple types of disabilities and stay current on effective practices and policies. Confirm digital accessibility across systems and vendors. Ensure the organization’s website, applicant tracking system, products/services, and key vendor platforms meet the ADA and Web Content Accessibility Guidelines (WCAG) accessibility requirements. In addition, verify that your stakeholders, subsequent subcontractors, and vendors understand both Section 503 and Section 508 obligations.

Review Job Requirements on a Defined Cadence

Periodically evaluate job descriptions and qualification standards to confirm that all your job descriptions and postings include occupational requirements which are current, relevant to the position, and non-exclusionary without reason. Revise outdated language which could create unnecessary barriers for individuals with disabilities. For example, “Must be able to lift 50 pounds.” Unless the core responsibilities of the job require the candidate to lift 50 pounds or more, consider changing the job description requirement to a range much like the following, “Minimally must lift 25 pounds without assistance; may lift over 25 pounds with or without assistance.”

If you have any questions regarding the information provided above or wish to learn more about my experience managing over 100 audits, which included Section 503 compliance requirements, I am available to discuss these topics in greater detail, and provide insights as to your specific instance. I welcome you to use the insights shared here to develop a program tailored to your needs.

For further details on Section 503, DirectEmployers offers several resources available in DE Connect, as well as past blog posts to provide guidance:

• What is Section 503? How Do I Comply as a Contractor?
• An interactive Section 503 checklist of best practices (downloadable PDF available)>
• Jurisdictional Threshold Update for Section 503, as of 2026

In addition to being the “gold standard in VEVRAA compliance” DirectEmployers also offers a suite of solutions for Section 503 outreach and support—all as part of its Membership. From job delivery to vocational rehabilitation counselors around the country to an in-house certified ADA coordinator, Michelle Krefft, who can provide guidance program reviews, assistance and insights to help you further develop your disability inclusion programs.

National Disability Employment Awareness Month (NDEAM)

Finally, make sure to mark your calendars for this year’s National Disability Employment Awareness Month (NDEAM)! During the month of October, the Office of Disability Policy (ODEP) will once again be “Celebrating Value and Talent,” carrying the spirit of last year’s celebration forward through 2026 in honor of America’s 250th birthday. Stay tuned for more from DirectEmployers on how you can celebrate alongside us!