AskEARN | Federal Contractor Requirements Skip to main content

Welcome to AskEARN’s new website. As we transition to our new site, you can still visit EARN’s previous site.

About EARN

The Employer Assistance and Resource Network on Disability Inclusion (EARN) offers information and resources to help employers recruit, hire, retain and advance people with disabilities; build inclusive workplace cultures; and meet diversity, equity, inclusion and accessibility (DEIA) goals. 

Getting Started

Start here to learn how to recruit, hire, retain and advance people with disabilities; why workplace inclusion of people with disabilities matters; and how EARN’s resources can help.

A woman in a wheelchair addresses three colleagues around a small table

    Phases of Employment

  • A woman in a wheelchair shakes hands with a colleague

    Recruit

    Build a pipeline of talent that includes people with disabilities.

  • Two men work at repairing an engine.

    Hire

    Identify people who have the skills and attributes for the job.

  • A woman with a disability wearing a helmet works in a factory

    Retain

    Keep talented employees with disabilities, including those who acquire them on the job.

  • A man uses sign language to communicate.

    Advance

    Ensure that employees with disabilities have equal opportunities for advancement.

Dinah Cohen Learning Center

EARN’s Learning Center offers a wide range of training resources, including self-paced online courses.

Woman using assistive technology on a computer workstation.

News & Events

EARN makes it easy to stay up-to-date on disability employment news and information. Start by subscribing to our monthly newsletter and eblasts, which will connect you to upcoming events, developing news and promising practices in the world of disability diversity and inclusion. And don’t forget to follow EARN on Facebook, Twitter and LinkedIn

A smiling man with an earpiece sits in a wheelchair

Federal Contractor Requirements

Learn about obligations federal contractors have under Section 503 of the Rehabilitation Act, and strategies to meet them.

Federal contractors must meet specific equal employment and affirmative action requirements to ensure that their workforces are inclusive of people with disabilities. This page explains what a federal contractor is, what these requirements are and how to ensure your organization is meeting these requirements.

Who is a Federal Contractor?

Federal contractors are businesses or organizations that enter into a contractual agreement with any department or agency of the United States Government to perform a specific job, supply labor and/or materials, or for the sale of products and services. A federal subcontractor is a company that enters into a contractual relationship with a federal contractor to fulfill the work of a federal contract.

As a part of doing business with the Federal Government, both federal contractors and subcontractors must meet certain obligations and are prohibited from discriminating against qualified job applicants or employees on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, disability or status as a protected veteran. Covered federal contractors and subcontractors are also required to take affirmative action (e.g., proactive steps) to ensure that all applicants and employees are treated fairly in all areas of employment including recruitment, hiring, promotion, retention and compensation.

These requirements are outlined in three laws that are enforced by the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP). They are:

Under these laws, all covered government contract and subcontract must include an Equal Employment Opportunity (EEO) clause. EEO clauses specify the non-discrimination and affirmative action obligations each contractor or subcontractor assumes as a condition of its contract or subcontract. Learn about strategies to help federal contractors meet their obligations under Section 503 of the Rehabilitation Act and recruit, hire, advance and retain workers with disabilities.

Affirmative action goes beyond equal employment opportunity, and requires targeted outreach efforts to facilitate recruiting, hiring, retaining and advancing employees from diverse backgrounds. While covered federal contractors and subcontractors (and federal agencies, under different regulations) are required to take affirmative action and develop written affirmative action plans, some employers voluntarily adopt affirmative action plans to create a more inclusive workforce.

Disability-Related Requirements

Two of the three laws enforced by OFCCP—Section 503 and VEVRAA—pertain to people with disabilities, either directly or indirectly.

Section 503 directly focuses on people with disabilities. The law prohibits employers with federal contracts (or subcontracts) who have contracts with the federal government of at least $15,000 from discriminating against applicants and employees with disabilities, and requires them to take affirmative steps to hire, retain and promote people with disabilities. In 2014, updates to Section 503 strengthened its affirmative action requirements and introduced a 7% utilization goal. These updates also set a requirement that covered employers invite applicants and employees to self-identify as people with disabilities (applicants at both the pre- and post-offer stage and employees every five years). 

Learn about strategies to help federal contractors meet their obligations under Section 503 and recruit, hire, advance and retain workers with disabilities.

VEVRAA has an indirect disability component, in that it requires federal contractors and subcontractors with contracts in excess of $100,000 to take affirmative action to employ and advance in employment specified categories of veterans—one of which is disabled veterans—and prohibits discrimination against such veterans. In 2014, updates to VEVRAA strengthened these affirmative action obligations, including a requirement that employers establish annual hiring benchmarks for protected veterans. These updates went into effect at the same time as updates to Section 503. VEVRAA rules also require that covered employers invite applicants and employees to self-identify.

OFCCP offers a range of resources to assist federal contractors and subcontractors in meeting their recruitment, hiring and retention goals under Section 503.

Self-Identification of Employees with Disabilities

Given Section 503 and VEVRAA reporting requirements, employers covered by those laws should ensure that their workplace culture encourages self-identification. EARN’s publication, Engaging Employees to Measure Success: Innovative Approaches to Encouraging Self-Identification, provides strategies to assist, along with examples of internal efforts implemented by various companies.

Additionally, EARN’s Communicating the Benefits of Self-Identification: Five Steps to Success (PDF) resource provides process strategies employers can utilize to invite applicants and employees to self-identify not only for reporting requirements, but also as a way of conveying a company’s commitment to a disability-inclusive workplace.

Finding Job Candidates with Disabilities

Recruitment Tip: Work-based learning opportunities like internships and apprenticeships help employers build a diverse pipeline of talent, including people with disabilities. For more information on developing inclusive apprenticeship programs, visit the Partnership on Inclusive Apprenticeship’s (PIA) website. To learn more about inclusive internship programs, read the Department of Labor’s Inclusive Internship Programs: A How-To Guide for Employers (PDF).

Of course, getting an accurate count of current employees with disabilities is only one part of the equation. It is also important for federal contractors and subcontractors to ensure their recruiting and hiring processes are disability-inclusive.

Building relationships with state and local disability and workforce development service providers, such as state vocational rehabilitation agenciesAmerican Job CentersCenters for Independent Living (CILs) and other community-based organizations, can be beneficial for federal contractors seeking to proactively recruit people with disabilities and veterans in order to meet their goals under Section 503 and VEVRAA. These service providers can connect federal contractors with job seekers with disabilities directly or provide access to candidate databases. Since they have a strong local focus, they also can also assist in identifying and training individuals for specific workforce needs.

Relationships with service providers can be formed through formal partnerships (i.e., signed agreements outlining expectations from both parties) and/or informal interactions (i.e., ongoing contact regarding job openings and candidates). These organizations can help provide job candidates as well as supports that help bring people with disabilities on board—and ensure their success for years to come. For more information on state and local resources that can help federal contractors recruit and hire people with disabilities, visit Finding Candidates with Disabilities.