Federal Contractor Checklist: Cleaning Up Pre-Offer Disability Questions After CC-305 Ends

If your applicant tracking system still asks candidates to check a disability box before an offer, delete that pre-offer step. That does not mean you can stop asking about ability to do the job. The OFCCP issued a rule on August 21, 2026, ending the disability self-identification requirement, with the end date set for September 21, 2026.

The federal deadlines are fixed

The DOL ended the use of the CC-305, the voluntary disability self-identification form federal contractors had used since 2013. After September 21, 2026, federal contractors are no longer required to apply the seven-percent disability utilization goal under Section 503. The regulatory rescission tied to Executive Order 11246 becomes effective on October 26, 2026.

Put each change on the compliance calendar. The disability cleanup is one item, not the whole federal update. Good practice still means asking only what the job needs.

The offer separates two different questions

Before an offer, keep disability questions out of the screen. After an offer, tie the question to the job. Under the ADA, employers cannot ask disability questions before making a job offer, and any post-employment disability question must be job-related and consistent with business necessity. A post-offer medical exam can ask about ability to perform job duties, but it cannot be used to collect general medical history. Hold accommodation requests separate from hiring screens. A candidate who asks for an accommodation before an offer is not giving you permission to ask disability questions.

If your ATS has multiple steps, check each one: application, consent, background check, medical exam, accommodation request, and onboarding. A disability box in any pre-offer step is a problem. The fix is not to move the box to a later date. Delete the pre-offer ask and retain only the job-related post-offer ask.

Run the cleanup before onboarding

Run this list before your next onboarding cycle. Each item is a yes/no check, not a policy rewrite. The first two items remove the federal disability ask, the third preserves the post-offer limit, the fourth protects the veteran process, the fifth documents the state-law check, and the last two keep the program and records honest.

• Search your applicant tracking system for CC-305 and confirm the form is absent from pre-offer documents.
• Search pre-offer screens for disability language and confirm no disability self-identification question appears before an offer.
• Confirm post-offer disability questions stay within the job-related, business-necessity limit.
• Confirm VEVRAA veteran self-identification, data collection, and hiring benchmarks remain intact in the onboarding file.
• Confirm the state-law answer is documented before deleting any disability collection.
• Confirm the written Section 503 affirmative action program remains in place if you are a covered federal contractor meeting the 50-employee and $50,000 contract thresholds.
• Confirm the affirmative action program records reflect the change.

Tell recruiters and hiring managers that the pre-offer disability box is gone. A short email is enough: stop using the pre-offer disability form, limit post-offer questions to the job, and preserve veteran self-identification. Archive the prior form and prior instructions. Do not shred them. Retain them long enough to explain past data collection. If you use a third-party onboarding vendor, send them the same instruction. Their template may still contain the old box. A vendor update is not optional if the vendor is completing the pre-offer packet for you. The cleanup is easier when the owner is named.

State law and the program file are the easy misses

State law can create a separate collection duty. If your state requires disability data, leave that field in place and label it separately. Do not let the federal cleanup delete a state requirement. If you collect veteran status, retain the same voluntary form, same timing, and same data handling. Do not merge it with the disability field you are deleting.

The affirmative action program still needs a clean note. It should show what changed, what stayed, and where the prior form is archived. That note is not a legal filing. Reviewers will look for it first. If your program still references the removed utilization target, update the language. If it still references the prior form, update the references. The file should be easy to follow in a review.