OFCCP Announces Increased Jurisdictional Thresholds for VEVRAA and Section 503: What Federal Contractors Should Do Now

The Office of Federal Contract Compliance Programs (OFCCP) just announced updated jurisdictional thresholds for two key federal affirmative action laws: the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) and Section 503 of the Rehabilitation Act (Section 503). These changes, announced on November 25 and driven by the government’s latest inflation adjustments, took effect on October 1, 2025. Since they may alter which employers are covered going forward, contractors should ensure they are familiar with the new standards – and have a gameplan going forward.

Updated Thresholds

The “jurisdictional thresholds” are the dollar and size cut‑offs that determine when OFCCP’s Section 503 and VEVRAA rules apply to a contractor. Given last week’s announcement, the new standards are:

• Section 503: The basic coverage threshold has increased from $15,000 to $20,000.
• VEVRAA: The coverage threshold has increased from $150,000 to $200,000.

These updates do not change the long-standing conditions for when a contractor must maintain a written Affirmative Action Program (AAP). Employers with 50 or more employees must continue to maintain an AAP if they hold:

• A single contract of $50,000 or more under Section 503; or
• Now, a single contract of $200,000 or more under VEVRAA.

Although the administration rescinded Executive Order 11246’s affirmative action requirements, VEVRAA and Section 503 remain in full force, including their nondiscrimination and affirmative outreach obligations.

Impact on Federal Contractors and Subcontractors

For organizations working close to the prior dollar thresholds, these increases may materially affect coverage.

• Some contractors that previously triggered obligations under VEVRAA or Section 503 may now fall below the new levels and therefore no longer be subject to certain requirements.
• However, contractors that meet the new thresholds must continue to comply with all applicable recordkeeping, self-identification, accommodation, and outreach obligations.

Because the threshold changes do not alter the underlying statutes, organizations that continue to meet or exceed the revised values remain fully subject to VEVRAA and Section 503 requirements.

Recommended Compliance Steps

To help organizations assess the impact of these changes and maintain compliance, we recommend the following steps:

1.  Conduct a Comprehensive Contract Review

Inventory all current federal contracts and subcontracts, including their dollar value, duration, and any amendments. Give special attention to those contracts near the former thresholds. Though, if you have any single contract that meets the threshold, your organization has compliance obligations under Section 503 and VEVRAA.

2. Reassess Coverage Status

Determine whether your organization still meets the updated jurisdictional thresholds:

• If contract values fall below $20,000 (Section 503) or $200,000 (VEVRAA), the organization may no longer be covered.
• If contract values exceed the AAP triggers and workforce requirements remain satisfied, ensure that AAPs for protected veterans and individuals with disabilities are properly maintained.

3.  Monitor OFCCP Guidance

Enforcement priorities continue to evolve, particularly in light of recent regulatory shifts. Contractors should remain attentive to new OFCCP announcements or compliance initiatives that may follow these threshold updates.

Conclusion

If you have questions, reach out to your Fisher Phillips attorney, the author of this Insight, or any member of our Government Contracting, Compliance, and Reporting Practice Group. We will continue to monitor developments related to all aspects of workplace law. Make sure you are subscribed to Fisher Phillips’ Insight System to get the most up-to-date information.