VETS-4212 Deadline: Filing Window, Requirements, and Penalties

The VETS-4212 deadline is September 30 every year, with the filing window opening August 1. Federal contractors and subcontractors that held a covered contract during the prior calendar year must submit their veteran employment report inside that two-month window. Miss it and federal law bars any agency from awarding you a new covered contract until the report is filed.¹

The Filing Window

The cycle runs August 1 through September 30 following any calendar year in which you held a covered federal contract or subcontract.² Reports submitted before August 1 or after September 30 fall outside the official cycle. The regulation does not extend the deadline when September 30 lands on a weekend or federal holiday, so treat the calendar date as firm and submit ahead of it.

The filing window is not the same as the reporting period. Your workforce numbers must come from a payroll period that ended between July 1 and August 31 of the current filing year, and the twelve months preceding that payroll ending date become the reporting period for new hires and headcount ranges.

What Happens If You Miss the Deadline

The immediate consequence is a contracting bar. Under 31 USC 1354, no federal agency may obligate or spend appropriated funds to enter a covered contract with a contractor that failed to file the required VETS-4212 report for the preceding fiscal year.¹ The bar stays in place until you file. For companies that rely on federal work, even a brief gap in eligibility can cost far more than the report itself.

Non-compliance also puts you on OFCCP’s radar. The agency uses VETS-4212 data in its compliance evaluations, and a missing report can trigger a broader review of your affirmative action obligations under VEVRAA. If violations are found, available sanctions include cancellation or termination of existing contracts, withholding of progress payments, and debarment from future federal contracting.³ Debarment is rare and reserved for serious or repeated violations, but it is on the table.

The practical takeaway: filing late is better than not filing, because the contracting bar lifts as soon as you submit. Filing on time avoids the bar and the scrutiny.

Who Has to File by September 30

The Department of Labor lists the current VETS-4212 threshold as a federal contract or subcontract of $150,000 or more.⁴ Any employer at or above that dollar figure must file, whether prime or subcontractor, regardless of location size.⁵ Private companies, nonprofits, and educational institutions are all covered if they hold qualifying contracts.

One wrinkle: the Federal Acquisition Regulation lists the VEVRAA applicability threshold at $200,000 after inflationary adjustments, while DOL’s VETS-4212 page still lists $150,000.⁶ Until DOL updates its guidance, contractors sitting between $150,000 and $200,000 are safer filing. There is no penalty for filing when you did not strictly owe a report, and there are real penalties for skipping one you did owe.

A few situations sit outside the requirement: state and local government activity not performed under a federal contract, contracts below the threshold as of January 1, worksites outside the United States and its territories, subsidiaries that are not themselves federal contractors or subcontractors, and acquired or merged entities that no longer maintain a separate identity. Purchase orders and lower-tier subcontracts are easy to overlook, so review them before you assume you are exempt.

How to Submit Before the Deadline

DOL accepts three submission methods. Electronic filing through the VETS-4212 online application is the most direct route for single-location filers, and the system emails a confirmation that serves as proof of timely compliance.⁴

Contractors with more than ten hiring locations must file electronically using the batch upload process. The system accepts CSV files in plain ASCII text, and several fields require specific formatting, including padded zip codes, phone numbers, NAICS codes, and EIN numbers. Employment count columns need zeros rather than blank cells.⁷ Formatting errors are the leading cause of batch rejections, so validate against DOL’s specifications before uploading. Once inside the filing window, a rejected batch you have to rework can eat days you may not have.

Paper filing is also allowed. The form can be emailed to vets4212-customersupport@dolncc.dol.gov or mailed to the VETS-4212 Submission office in Falls Church, Virginia.⁴ Paper and email routes take longer to process. If you are close to September 30, the online portal gives you an instant timestamp and removes any argument about whether you filed on time.

What You Need Ready Before You File

The form collects three core data sets from your reporting period, broken out by job category and hiring location:⁸

Total number of employees and the number who are protected veterans, broken down by job category and hiring location.
Total number of new employees hired during the reporting period and the number of those new hires who are protected veterans.
Maximum and minimum number of employees at each hiring location during the reporting period.

Job categories align with the EEO-1 classifications, so HR teams already producing that report can reuse the framework. DOL offers both a standard VETS-4212 form and an EEO-1 aligned version.⁴

Your veteran counts are only as good as your self-identification process. Federal contractors must invite employees to voluntarily disclose protected veteran status using a form that follows the OFCCP template, keep participation voluntary, and keep the information confidential.⁹ Gaps in self-ID mean undercounted veterans on your report, and undercounts can draw scrutiny during a compliance evaluation.

Multi-location employers file a separate report for each hiring location plus a consolidated headquarters report. State consolidated reports each count as one location when you calculate whether you have crossed the ten-location threshold that requires batch upload.²

Records to Keep After Filing

Submitting the report is not the end of your obligations. OFCCP requires contractors to retain affirmative action program records, including VETS-4212 filings and the underlying data, for at least three years from creation. Personnel and employment records such as applicant logs, hire documentation, and self-identification forms must be kept for two years from when the record was made or the personnel action was taken, whichever is later. Contractors with fewer than 150 employees have a one-year retention period for personnel records.¹⁰

Keep copies of each filed VETS-4212 report along with the payroll data, self-identification responses, and new hire records used to build your numbers. If OFCCP opens a compliance evaluation, they will ask how you arrived at the figures you reported, and organized records turn that request into a short exchange rather than a scramble.

1
Office of the Law Revision Counsel. 31 USC 1354 – Limitation on Use of Appropriated Funds for Contracts With Entities Not Meeting Veterans Employment Reporting Requirements
2
eCFR. 41 CFR 61-300.11 – When and How Should Federal Contractors and Subcontractors File VETS-4212 Reports
3
U.S. Department of Labor. Employment Nondiscrimination and Equal Opportunity for Covered Veterans
4
U.S. Department of Labor. VETS-4212 Federal Contractor Reporting
5
U.S. Department of Labor. a href=”https://www.dol.gov/agencies/vets/contractor” target=”_blank” rel=”noopener”>Federal Contractor Reporting
6
Acquisition.GOV. FAR – 22.1303 Applicability
7
U.S. Department of Labor. VETS-4212 Batch Filing Frequently Asked Questions
8
eCFR. 41 CFR 61-300.10 – What Reporting Requirements Apply To Federal Contractors and Subcontractors
9
U.S. Department of Labor. Sample VEVRAA Self-Identification Form
10
U.S. Department of Labor. Understanding OFCCP Recordkeeping Requirements