The Government Accountability Office (GAO) recently recommended that the Department of Labor strengthen its oversight of federal contractors’ compliance with Section 503, the law that prohibits disability discrimination and requires covered federal contractors to take certain steps to support employment opportunities for individuals with disabilities.
The GAO recommended that the Department of Labor resume Section 503 audits and contractor certifications, improve its compliance guidance, and provide additional resources to help employers recruit and support individuals with disabilities.
The Department of Labor has agreed with six of the GAO’s eight recommendations. However, it has not committed to resuming routine audits or Section 503 AAP certifications at this time. The department says it is reviewing its compliance activities following recent regulatory changes and continues to investigate complaints.
What does this mean for your organization?
The GAO report does not create new compliance requirements. Covered federal contractors should continue meeting the Section 503 obligations that remain in effect.
Following the September 2026 regulatory changes, employers should review their procedures to ensure they reflect the removal of the former disability self-identification process, Form CC-305 requirement, and 7% utilization goal.
Other obligations remain important, including:
- Maintaining a written Section 503 Affirmative Action Program (AAP) when required.
- Continuing appropriate outreach and recruitment efforts for qualified individuals with disabilities.
- Assessing the effectiveness of those outreach and recruitment efforts.
- Providing reasonable accommodations as required by law.
- Maintaining documentation supporting compliance with applicable requirements.
Our recommendation: Do not interpret the suspension of routine audits as a suspension of your compliance responsibilities. Review your current Section 503 program, update procedures affected by the regulatory changes, and continue monitoring official DOL and OFCCP guidance.
Lighthouse Compliance Solutions will continue monitoring these developments and sharing relevant updates.
For questions contact Greta Gay:
1-501-658-8883