Disability Self-Identification Form Approved for Use by Federal Contractors Through July 2029

Federal contractors subject to the Rehabilitation Act of 1973 are required to invite applicants and employees to self-identify as to disability and, in doing so, must use a form published by the Office of Federal Contract Compliance Programs (OFCCP) for this purpose. Like all forms used by the government for a general collection of information, this form – known as Form CC-305 – must be periodically reviewed by the Office of Management and Budget (OMB) and approved for continued use. 

Approval of the current form expired on April 30, 2026, and there were questions as to whether the form would be reauthorized in light of OFCCP’s July 8, 2025, proposal to not only rescind rules requiring contractors to invite applicants and employees to self-identify as to disability, but also to prohibit such inquiries. On July 16, 2026, however, OMB approved Form CC-305 for continued use through July 31, 2029, with no changes from the prior version of the form. The current version of the form, showing the new expiration date, can be downloaded from links on the OFCCP’s website.

Covered federal contractors and subcontractors should begin using the new form as quickly as possible. As the only change will be to the expiration date at the top of the form, this should not be too difficult to accomplish. Contractors must continue to use the OFCCP’s prior form until they have implemented the revised form.

Approval of the new form does not necessarily mean that OFCCP will be walking away from its proposal to prohibit employers from soliciting information from applicants and employees regarding disability. OFCCP could still move forward with its proposal to amend the rules at 41 CFR Part 741 to end this requirement. However, substantial opposition to the rule change combined with this development might be an indication that the affirmative action requirements relating to individuals with disabilities will not be substantially changed. 

We will continue to watch for the publication of new final rules pursuant to VEVRAA and Section 503.