OFCCP's New Section 503 Final Rule: What Higher Education Institutions Need To Know

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September 24, 2026 2:00 PM – 3:00 PM EST

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On August 21, 2026, the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) published a final rule significantly changing disability-related affirmative action requirements for federal contractors under Section 503 of the Rehabilitation Act. The rule eliminates the requirement that covered employers invite applicants and employees to self-identify as individuals with disabilities, rescinds the related Form CC-305 and disability data collection requirements and removes the longstanding 7% utilization goal and associated utilization analyses.

For colleges and universities that are federal contractors or subcontractors, these changes represent a substantial shift in how disability affirmative action programs are administered. While many disability-related data collection obligations are being eliminated, institutions remain subject to Section 503's affirmative action and nondiscrimination requirements, as well as their obligations under the Americans with Disabilities Act (ADA) and Sections 504 and 508 of the Rehabilitation Act.

Join Jackson Lewis P.C. attorneys for a timely discussion of what the final rule changes, what stays in place and what federal contractors and subcontractors should be doing now to update their compliance programs.

Topics

• How the final rule changes disability-related affirmative action requirements for colleges and universities that are federal contractors
• What obligations remain under Section 503, the ADA, and Sections 504 and 508 of the Rehabilitation Act
• Whether and when institutions may collect disability-related information from applicants, faculty, staff and employees following the elimination of mandatory self-identification invitations
• The impact of the rule on faculty and staff affirmative action programs, outreach efforts and disability inclusion initiatives
• Alternative approaches for evaluating the effectiveness of disability recruitment, outreach and retention efforts without utilization goals or workforce disability data
• Practical considerations for updating applicant tracking systems, onboarding materials, accommodation procedures, affirmative action plans and website disclosures
• Key considerations for institutions that previously relied on disability self-identification data to measure inclusion and accessibility efforts

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