Before October 26: Stop, Keep, and Document Your OFCCP AAP File

The cutoff is a file edit

Your OFCCP file has two dates that matter. Executive Order 14173, issued on January 21, 2025, revoked Executive Order 11246. The rule package ends the Executive Order 11246 implementing regulations on October 26, 2026. It narrows Section 503 disability duties and changes VEVRAA coverage and enforcement rules on September 21, 2026.

The final rule removes the regulatory text for the old order's equal opportunity clause, the nonconstruction affirmative action program rules, construction contract specifications, and sex-discrimination interpretations. Before the rescission, nonconstruction contractors measured each job group against labor-market availability for race, ethnicity, and sex. When minorities or women were underrepresented, they set placement goals no lower than availability.

The race and sex affirmative-action program stops. The job-group utilization work tied to that program stops with it. The stopped work is the old order's race and sex program, not the retained disability and veteran duties. Close that part of the file cleanly.

Section 503 and VEVRAA keep their core duties

Section 503 disability duties do not disappear. Covered contractors and subcontractors with at least 50 employees and a contract of at least $50,000 must keep a written Section 503 affirmative action plan and continue disability-related outreach and positive recruitment. The rule no longer requires disability utilization analyses or voluntary disability self-identification from applicants and employees.

VEVRAA veteran duties also continue. The rule keeps annual veteran affirmative action plans, a veteran hiring benchmark, veteran self-identification requests, data analyses, and outreach. The covered-contractor threshold changes from $150,000 to $200,000. The threshold change can move a contractor in or out of coverage. If your contract value is near the new line, re-run coverage before you stop any veteran work.

If you collect voluntary data for internal review, label it as a business decision, not as a response to the old federal-contractor program. Keep the retained programs in separate folders so the cutoff does not blur the duties that remain. Cross-reference the old file to the new file, but do not merge the stopped worksheets into the active plan.

The checklist does the file edit

Use the list as the file edit. Each item is a yes/no check. The list follows the cutoff: stop the old race and sex work, keep the disability and veteran duties, then record the line.

• Mark the Executive Order 11246 race and sex program as inactive as of October 26, 2026.
• Stop preparing job-group utilization analyses for race, ethnicity, and sex.
• Remove the old equal-opportunity clause compliance work from the active file.
• Keep the written Section 503 plan if you have at least 50 employees and a contract of at least $50,000.
• Continue disability outreach and positive recruitment.
• Do not rely on the removed disability utilization or self-identification requirements.
• Keep the annual VEVRAA plan, the veteran hiring benchmark, the self-identification request, the data analyses, and the outreach.
• Check whether the VEVRAA threshold change to $200,000 affects your coverage.
• Record the cutoff date, the stopped items, and the retained duties in the file.

Documentation makes the cutoff defensible

A short memo should carry the cutoff. State the date the race and sex program stopped. Name the job-group analyses that are no longer required. Identify the Section 503 plan, the disability outreach, the annual veteran plan, the benchmark, the self-identification request, the data analyses, and the veteran outreach that remain. Note the employee count and contract value used to test coverage.

Assign one owner for the cutoff note. Keep the memo with the active file, not buried in the archive. That owner should be able to explain the change to a reviewer without pulling the old worksheets.

Keep the old file, but label it clearly. Put the stopped worksheets in a closed archive. Do not use them for new placement goals. The cutoff note should show the file was edited, not abandoned.