AAP Reporting Requirements for Federal Contractors

AAP reporting requirements for federal contractors changed sharply in 2025. Executive Order 14173 revoked Executive Order 11246 in January 2025, ending the race, sex, and ethnicity affirmative action program that had anchored contractor compliance since 1965. What survived is still substantial: the EEO-1 Component 1 report under Title VII, the VETS-4212 report and written veterans AAP under VEVRAA, and the written disability AAP under Section 503 of the Rehabilitation Act. If you hold a qualifying federal contract, those three obligations are what you plan around now.¹

The Department of Labor has moved to formally rescind the E.O. 11246 implementing regulations, and the OFCCP’s Contractor Portal for AAP certification is closed while the agency revises its systems. Section 503 and VEVRAA, along with their implementing regulations, remain fully in effect.²

EEO-1 Component 1: The Workforce Demographic Report

The EEO-1 filing requirement is grounded in Title VII, not E.O. 11246, so the revocation did not touch it. Two thresholds decide whether you file. Private employers who are not federal contractors file if they have 100 or more employees. Federal contractors and first-tier subcontractors file at a lower bar: 50 or more employees plus a federal contract or subcontract of $50,000 or more.³

The report categorizes every employee by sex, race, and ethnicity across ten standard job categories running from executive and senior-level officials down through service workers. Data must reflect a single pay period, the workforce snapshot period, which you select from any pay period between October 1 and December 31 of the reporting year.⁴ Picking a pay period that reflects typical staffing, rather than a seasonal spike or lull, produces cleaner data.

Filing happens through the EEOC’s online Component 1 system. The window varies from year to year. For the 2024 data collection, it opened May 20, 2025 and closed June 24, 2025 with no extensions granted.⁵ After upload, an authorized company official certifies the submission. Keep the system’s confirmation as proof of timely filing.

Multi-establishment employers cannot file one consolidated report for the whole company. They file a headquarters report, an individual report for each establishment with 50 or more employees, and a consolidated report rolling up all locations. Smaller sites can be grouped on the consolidated report instead of filed individually.

VETS-4212: Annual Veterans Employment Report

If you hold a federal contract of $150,000 or more, you must file the VETS-4212 report annually with the Department of Labor under VEVRAA.⁶ The report covers employment and hiring of protected veterans in four categories: disabled veterans, recently separated veterans (discharged within the past three years), active duty wartime or campaign badge veterans, and Armed Forces service medal veterans.

You report the number of protected veterans employed and the number of new veteran hires, broken down by job category. The filing window runs from August 1 through September 30 each year, and submission is electronic through the Department of Labor’s VETS-4212 online system.⁷ VEVRAA also requires a written AAP for protected veterans, separate from anything the old E.O. 11246 program required.

Section 503: Written Disability AAP and Self-Identification

Section 503 of the Rehabilitation Act operates independently from the revoked E.O. 11246 requirements. Any contractor with a federal contract exceeding $20,000 must not discriminate against qualified individuals with disabilities. If you have 50 or more employees and a single contract of $50,000 or more, you must also develop a written Section 503 Affirmative Action Program.⁸

You must invite applicants and employees to voluntarily self-identify their disability status. Individual responses stay confidential, but you track the aggregated data against OFCCP’s 7% utilization goal. For contractors with more than 100 employees, the 7% target applies to each job group separately. Contractors with 100 or fewer employees can measure against the entire workforce.⁹ The goal is aspirational rather than a rigid quota, but OFCCP uses it as a benchmark during compliance reviews. If you fall short, document your good-faith outreach and recruitment efforts.

Record Retention

With the E.O. 11246 regulations being rescinded, the retention rules that matter now come from Section 503 and VEVRAA, and the two frameworks are nearly identical.

Keep personnel and employment records for at least two years from the date the record was created or the personnel action occurred, whichever is later. That covers applicant flow data, hiring and promotion decisions, compensation details, and termination documentation. Contractors with fewer than 150 employees, or without a government contract of at least $150,000, can use a shorter one-year retention period.¹⁰

Some records carry a three-year retention. Under Section 503, that applies to outreach and recruitment documentation for individuals with disabilities and to annual computations comparing applicants and hires with disabilities against overall applicant and hire totals. Apply the same three-year standard to VETS-4212 filings and their supporting data, since VEVRAA’s retention framework mirrors Section 503.

Enforcement and Penalties

Consequences depend on which filing you miss. For EEO-1 failures, the EEOC can file a federal lawsuit to compel compliance, and it has done so, suing multiple employers in a single enforcement action for refusing to submit the required data.¹¹

For Section 503 and VEVRAA, OFCCP conducts compliance reviews that begin with a desk audit and can escalate to an on-site investigation. You typically receive a scheduling letter and 30 days to produce the requested documentation. If OFCCP finds violations, enforcement can include orders to pay back wages with interest, reinstate employees, or hire affected applicants. Serious cases can lead to debarment from future federal contracts. OFCCP recently resumed processing Section 503 and VEVRAA complaints after a temporary hold, so active enforcement in these two areas is underway.²

1
Federal Register. Rescission of Executive Order 11246 Implementing Regulations
2
U.S. Department of Labor. Office of Federal Contract Compliance Programs
3
U.S. Equal Employment Opportunity Commission. EEO Data Collections
4
U.S. Equal Employment Opportunity Commission. EEO-1 Employer Information Report Statistics
5
PayrollOrg. 2024 EEO-1 Data Collection Due June 24
6
U.S. Department of Labor. VETS-4212 Federal Contractor Reporting
7
U.S. Department of Labor. Federal Contractor Reporting
8
U.S. Department of Labor. Jurisdiction Thresholds and Inflationary Adjustments
9
eCFR. 41 CFR 60-741.45 – Utilization Goals
10
eCFR. 41 CFR Part 60-741 – Affirmative Action and Nondiscrimination Obligations of Contractors and Subcontractors Regarding Individuals With Disabilities
11
U.S. Equal Employment Opportunity Commission. EEOC Sues 15 Employers for Failing to File Required Workforce Demographic Reports