VETS-100 Reporting Requirements: Filing, Deadlines, and Penalties

If your company holds a single federal contract or subcontract worth $200,000 or more, the VETS-4212 reporting requirements obligate you to file an annual report with the Department of Labor showing how many protected veterans you employ and hired during the reporting period. The report is due between August 1 and September 30 each year, and the contract threshold rose from $150,000 to $200,000 for contracts entered into or modified on or after October 1, 2025.¹

Who Has to File

The filing duty comes from 38 U.S.C. § 4212, which requires any company holding a qualifying federal contract or subcontract to take affirmative action in hiring veterans and to report annually on its progress.² The threshold looks at a single contract’s value, not the combined total of all your government work. Five separate $50,000 contracts do not add up to a covered relationship.

The rules at 41 CFR Part 61-300 spell out the reporting mechanics, and FAR Subpart 22.13 builds the requirement into the contracting process, so once you sign a qualifying contract the VETS-4212 obligation is a contract term.³ Subcontractors performing work under a covered prime contract have the same duty if their subcontract meets the threshold.

Contracts signed before October 1, 2025 were governed by the previous $150,000 threshold. If you hold pre-October 2025 contracts in the $150,000 to $199,999 range and have not modified or renewed them, those contracts still carry the reporting requirement. A modification after the effective date brings the new $200,000 figure into play.¹

Who Counts as a Protected Veteran

The VETS-4212 tracks four categories. Your report has to reflect these accurately, which means your intake process has to capture them:

Disabled veterans, meaning veterans with a service-connected disability or those discharged from active duty because of a service-connected disability.
Recently separated veterans, defined as anyone within three years of discharge or release from active duty.³
Active-duty wartime or campaign badge veterans, meaning those who served during a war or in a campaign for which a campaign badge was authorized.
Armed Forces service medal veterans, meaning those who participated in a military operation that earned an Armed Forces service medal under Executive Order 12985.⁴

One person can qualify under more than one category. The form asks whether an employee is a protected veteran, not which specific category applies, so overlap does not create double counting on the report itself.

Getting the Data: Self-Identification

You cannot count protected veterans unless you ask. VEVRAA regulations require you to invite applicants to voluntarily self-identify as protected veterans at two points: before making a job offer and again after extending one.⁵ The pre-offer invitation can live inside your application materials. The post-offer invitation asks the applicant to identify which specific categories apply, because that detail feeds the report.

Self-identification is voluntary. An applicant can decline, and that choice cannot be used against them. The Department of Labor publishes a sample self-identification form that satisfies the regulation, and many contractors use it directly or adapt it to fit their HR systems.⁶ Whatever form you use, responses stay confidential and are kept separate from general personnel files.

What Goes in the Report

The report organizes your workforce by the ten standard EEO-1 job categories: officials and managers, professionals, technicians, sales workers, administrative support, craft workers, operatives, laborers, service workers, and a catch-all category. Within each category, you report:

Total employees in the job category.
Protected veterans in that category, based on self-identification.
New hires during the reporting period, and how many of those were protected veterans.
Maximum and minimum headcount on the payroll during the twelve-month reporting period.⁷

These figures have to reconcile to your underlying payroll and HR records. OFCCP can audit them.

Deadlines and the Reporting Period

The annual filing window opens August 1 and closes September 30.⁸ Your report covers a twelve-month period you choose, ending on any pay period between July 1 and August 31 of the reporting year. Many contractors align the end date with their EEO-1 cycle so they only pull a workforce snapshot once. Others report on the prior calendar year and use a December 31 end date.

Pick a period and stay with it. Switching year to year creates inconsistencies that complicate trend analysis and can raise flags during an OFCCP review. If you miss September 30, file as soon as you can, because late filing carries its own consequences.

How to Submit

The Department of Labor accepts the report through three channels:⁸

The VETS-4212 online filing system walks you through data entry and generates a confirmation of receipt. This is the common path for single-location contractors.
Email submission to vets4212-customersupport@dolncc.dol.gov.
U.S. mail to VETS-4212 Submission, Veterans’ Employment and Training Service Center, Department of Labor National Contact Center, 3110 Fairview Park Drive, Suite 800, Falls Church, VA 22042. Use a tracked delivery service so you can confirm arrival before the window closes.

Batch Filing for Multiple Locations

If you have multiple hiring locations, you submit a separate report for each one. Companies with more than ten locations are encouraged to use batch filing, which uploads all reports at once through a CSV file.⁹ The formatting rules are strict: zip codes must be zero-padded to five digits, DUNS numbers to nine, phone numbers to ten, and empty employee-count cells must contain zeros rather than blanks. Only specific special characters are allowed in company names and addresses. If your batch file consolidates reports across multiple states, you also need a secondary hiring-location file listing every location covered by the consolidation. Validate the file before uploading. Fixing a rejected batch during the last week of September is a bad place to be.

Related VEVRAA Obligations That Travel With the Report

Filing the VETS-4212 is one piece of VEVRAA compliance, not the whole of it. Covered contractors must also list virtually all job openings with the appropriate state or local employment service delivery system so that protected veterans get priority referrals.⁵ When you first register with the employment service, identify yourself as a federal contractor, request priority referrals, and provide contact information for the hiring official at each location in that state. For remote positions with no fixed duty station, you can list the opening with an employment service in any area where qualified candidates might reasonably be found. If a job can be performed on-site or remotely, list it where the physical duty station sits.

If your company has 50 or more employees and a single contract of $200,000 or more, you must also develop and maintain a written Affirmative Action Program for veterans under 41 CFR 60-300, Subpart C.¹⁰ The AAP is separate from the VETS-4212 and includes outreach strategies, internal audit procedures, and a hiring benchmark for protected veterans. The current national benchmark, set by OFCCP, is 5.1%.¹¹ The self-identification data you collect for the report also measures your progress against the benchmark.

Behind the filing sits a recordkeeping duty. Personnel and employment records, including applications, interview notes, hire decisions, promotions, terminations, and compensation data, must be kept at least two years from the date the record was created or the personnel action occurred, whichever is later. Contractors with fewer than 150 employees can use a one-year retention period.¹² AAP-related records, including the data behind your hiring benchmark, internal audit results, and outreach documentation, have a three-year retention requirement.

What Happens if You Don’t File

The immediate consequence is direct: federal agencies are prohibited from spending money on new contracts with a company that failed to file its VETS-4212 for the previous fiscal year.¹³ Contracting officers cannot obligate funds or enter new agreements with you until the missing report is submitted. Once you file, the freeze lifts, but the contract opportunities lost during the gap are gone.

OFCCP also uses VETS-4212 data in compliance evaluations, and a missing or incomplete report can trigger an investigation.⁸ Veterans who believe a contractor is not meeting its obligations can file complaints directly with the Secretary of Labor, who is required to investigate.² The enforcement mechanism is wired directly into the contracting process, and it works.

1
Acquisition.GOV. Threshold Changes – October 1st, 2025
2
Office of the Law Revision Counsel. 38 U.S. Code 4212 – Veterans Employment Emphasis Under Federal Contracts
3
Acquisition.GOV. Federal Acquisition Regulation Subpart 22.13 – Equal Opportunity for Veterans
4
U.S. Department of Labor. Federal Contractor Program
5
U.S. Department of Labor. Vietnam Era Veterans Readjustment Assistance Act Regulations
6
U.S. Department of Labor. Sample VEVRAA Self-Identification Form
7
U.S. Department of Labor. Federal Contractor Veterans Employment Report VETS-4212
8
U.S. Department of Labor. VETS-4212 Federal Contractor Reporting
9
U.S. Department of Labor. VETS-4212 Batch Filing Frequently Asked Questions
10
U.S. Department of Labor. Jurisdiction Thresholds and Inflationary Adjustments
11
U.S. Department of Labor. VEVRAA Hiring Benchmark
12
eCFR. 41 CFR 60-300.80 – Recordkeeping
13
Office of the Law Revision Counsel. 31 U.S. Code 1354 – Limitation on Use of Appropriated Funds for Contracts With Noncompliant Contractors