On July 2, 2025, the U.S. Department of Labor issued Secretary’s Order 08-2025, officially lifting the abeyance on the Office of Federal Contract Compliance Programs’ (OFCCP) enforcement activities under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). This follows the earlier suspension of these activities under Secretary’s Order 03-2025, which was issued in response to Executive Order (E.O.) 14173 revoking E.O. 11246.
Key developments include:
- Resumption of Investigations and Compliance Reviews: OFCCP will immediately resume processing Section 503 and VEVRAA complaints that were held during the abeyance. New complaints filed during the abeyance will also be processed.
- Administrative Closure of Pending Reviews: Due to the prior entanglement of E.O. 11246 with Section 503 and VEVRAA reviews, OFCCP will administratively close all pending compliance reviews from the November 2024 scheduling list. Affected contractors will receive formal notification.
- AAP Certification Period Remains Closed: While OFCCP revises its systems to reflect the revocation of E.O. 11246, the affirmative action program (AAP) certification period for Section 503 and VEVRAA remains closed.
Federal contractors should promptly resume compliance with Section 503 and VEVRAA obligations. They should also stay informed of future updates to OFCCP’s processes and certification timelines. Those under compliance investigations prior to November 2024 should look out for closure notifications.
Barley Snyder will continue to monitor developments as they occur. If you have questions about how the resumption of enforcement under Section 503 and VEVRAA may affect your organization’s compliance obligations, please reach out to Jennifer Craighead Carey or any attorney in Barley Snyder’s Employment Practice Group.
