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VEVRAA and Section 503 Affirmative Action Plan Template (2026)

VEVRAA explained for federal contractors: who needs a plan, the 5.1% hiring benchmark, 2026 rule changes, VETS-4212 and an AAP template with a free calendar.

VEVRAA and Section 503 Affirmative Action Plan Kit: printable page and spreadsheet preview

For HR and compliance teams at federal contractors

VEVRAA and Section 503 Affirmative Action Plan Kit

$149USD · one-time purchase · instant download

Write and maintain both affirmative action plans under the rules that took effect on 9/21/2026. Two editable Word AAPs with guidance and sample wording, a data workbook that calculates the VEVRAA numbers for you, and a guide with an annual calendar and audit-ready checklist.

  • VEVRAA AAP template: 16 sections following 41 CFR 60-300.44, with a sample policy statement, outreach assessment, data collection table and hiring benchmark worksheet
  • Section 503 AAP template rewritten for the 2026 rule: no self-ID, utilization goal or data collection analysis, plus an accommodation procedure and ICT accessibility review
  • Workbook: requisitions with a concurrent job-listing check, applicants, self-ID log, 3-year data collection (k), national or five-factor benchmark
  • Outreach effectiveness log, accommodation log, qualification standards review schedule, annual checklist and VETS-4212 prep from your roster
  • 7-page guide: who needs which plan, what changed in 2026, an annual calendar and an audit-ready checklist

You get: 2 Word templates · Excel workbook (Google Sheets-ready) · 7-page PDF guide

Secure checkout by Razorpay. Cards accepted worldwide, charged in US dollars. Files arrive on screen and by email. Refund policy

02

What is VEVRAA?

VEVRAA, the Vietnam Era Veterans' Readjustment Assistance Act of 1974, requires federal contractors to not discriminate against protected veterans and to take affirmative action to hire and advance them. Contractors with 50 or more employees and a contract of $200,000 or more must keep a written VEVRAA affirmative action plan.

VEVRAA is enforced by the Department of Labor's Office of Federal Contract Compliance Programs (OFCCP), and its rules are in 41 CFR part 60-300. It protects four groups of veterans (60-300.2): disabled veterans; recently separated veterans, within three years of discharge or release from active duty; active duty wartime or campaign badge veterans; and Armed Forces service medal veterans.

Its sister law, Section 503 of the Rehabilitation Act, requires affirmative action for individuals with disabilities (41 CFR part 60-741). Most contractors keep the two plans side by side, which is why this kit covers both. In 2026 the Department of Labor rewrote the Section 503 rules and rescinded the Executive Order 11246 regulations, so many contractors are checking what is left. The short answer: VEVRAA's requirements stay in force, with a higher dollar threshold.

Last reviewed: 25 October 2026. Every rule below links to the current eCFR text or the Federal Register; check them again before you finalize a plan.

03

Free printable VEVRAA and Section 503 annual compliance calendar (PDF)

Download the free annual AAP compliance calendar (PDF), page 6 of the kit's guide. It lays out a calendar-year plan month by month, from updating both AAPs and setting the hiring benchmark in January to the VETS-4212 window in August and September and the year-end outreach assessment in December, with the record retention periods at the foot of the page.

The full kit adds two editable Word affirmative action plan templates (VEVRAA and Section 503), the data workbook that calculates the (k) data and benchmark comparison, and the rest of the guide, including the audit-ready checklist.

04

Who is covered: 2026 thresholds

ObligationVEVRAASection 503
Basic coverage (nondiscrimination, equal opportunity clause)Contract or subcontract of $200,000 or more (60-300.1(b), 60-300.4)Contract or subcontract over $20,000 (60-741.1(b), 60-741.4)
Written affirmative action plan50 or more employees and a contract of $200,000 or more (60-300.40(a))50 or more employees and a contract of $50,000 or more (60-741.40(b)(1))
When the plan is dueWithin 120 days of the start of the contract, for each establishment; reviewed and updated every year; submitted within 30 days of an OFCCP request unless the request says otherwise (60-300.40, 60-741.40)

The VEVRAA threshold rose from $150,000 to $200,000, and the basic Section 503 threshold from $15,000 to $20,000, under the federal acquisition inflation adjustment effective October 1, 2025. The Department of Labor wrote the new amounts into its regulations effective September 21, 2026 (91 FR 54234; 91 FR 54482). Some older pages still show $150,000; the current eCFR text says $200,000.

05

What changed in 2025 and 2026

DateWhat happenedSource
January 21, 2025Executive Order 14173 revoked Executive Order 11246, the order behind race and sex affirmative action programs for contractorsOFCCP
January 24, 2025Secretary's Order 03-2025 stopped E.O. 11246 enforcement and put Section 503 and VEVRAA enforcement in abeyance; a later order, Secretary's Order 08-2025, lifted the abeyance for Section 503 and VEVRAAOFCCP
October 1, 2025Inflation adjustment: VEVRAA threshold to $200,000, Section 503 basic threshold to $20,00091 FR 54234; 91 FR 54482
August 21, 2026Three final rules published: VEVRAA modifications (91 FR 54234), Section 503 modifications (91 FR 54482) and rescission of the E.O. 11246 regulations (91 FR 54444)Federal Register
September 21, 2026VEVRAA and Section 503 rules take effect (the Section 503 amendment to part 60-30 is effective December 21, 2026)91 FR 54234; 91 FR 54482
October 26, 2026Rule rescinding the E.O. 11246 regulations (41 CFR parts 60-1, 60-2, 60-3, 60-4, 60-20, 60-40 and 60-50) is effective91 FR 54444

Section 503: the September 21, 2026 rule removed the invitations to self-identify disability (pre-offer, post-offer and the 5-year employee resurvey; the Department did not keep Form CC-305), the data collection analysis in 60-741.44(k), and the 7% utilization goal and analysis in 60-741.45. Contractors are not required to consider counts of applicants or hires with disabilities when judging outreach (60-741.44(l)). The Department's stated reason is that the invitations amount to disability inquiries the ADA restricts. The written Section 503 plan and its other elements still apply.

VEVRAA: the rule raised the threshold, moved enforcement procedures into part 60-300 and removed references to E.O. 11246. The pre-offer and post-offer self-ID invitations, the data collection analysis and the hiring benchmark were kept.

E.O. 11246: the rescission is effective October 26, 2026 and is not a VEVRAA or Section 503 change. OFCCP says Section 503 and VEVRAA and their regulations remain in effect and contractors should keep complying.

06

VEVRAA vs Section 503 at a glance

VEVRAASection 503
Who it protectsProtected veterans (four categories)Individuals with disabilities
Regulations41 CFR part 60-30041 CFR part 60-741
Written AAP50+ employees and $200,000+ contract50+ employees and $50,000+ contract
Self-ID invitationsPre-offer and post-offer, required (60-300.42)Rescinded September 21, 2026
NumbersAnnual data collection analysis (60-300.44(k)) and hiring benchmark (60-300.45)No utilization goal or data collection analysis since September 21, 2026
Mandatory job listingList openings with the state employment service delivery system (60-300.5)No equivalent
Annual reportVETS-4212None
Who may see the planEmployees and applicants, without the (k) data (60-300.41)Employees and applicants, full plan (60-741.41)
RecordsOutreach, (k) data and benchmark records 3 years (60-300.80(b))Outreach records 3 years (60-741.80(b))

07

What a VEVRAA affirmative action plan must contain

The required elements are listed in 41 CFR 60-300.44: a posted policy statement signed off by the top U.S. executive, a review of personnel processes, a schedule for reviewing physical and mental job qualifications, reasonable accommodation, harassment procedures, outreach and positive recruitment, internal dissemination, an audit and reporting system, a named responsible official, training, and a yearly data collection analysis.

  • Job listings: list every opening with the state employment service delivery system, such as the state job bank, at least at the same time as any other recruitment (60-300.5).
  • Self-identification: invite applicants to self-identify as protected veterans before any offer, and invite new hires to identify their specific category after the offer and before they start (60-300.42).
  • Data collection analysis: each year, count protected veteran applicants, job openings and jobs filled, total applicants, protected veteran hires and total hires, and keep the figures for 3 years (60-300.44(k)).
  • Hiring benchmark: each year, adopt the national benchmark OFCCP publishes, 5.1% since 7/30/2025 according to the DOL benchmark page, or set your own using five factors (60-300.45). It is a yardstick, not a quota.
  • Outreach assessment: each year, judge whether the past twelve months of outreach worked, using at least three years of the data above, and add new efforts if it did not (60-300.44(f)(3)).
  • VETS-4212: file between August 1 and September 30 for each hiring location (VETS).

08

VEVRAA hiring benchmark: 5.1% and how to use it

Each year you adopt a hiring benchmark, a percentage of hires you aim for that are protected veterans (60-300.45). You can use the national benchmark OFCCP publishes, which is 5.1% effective July 30, 2025 according to the DOL VEVRAA Hiring Benchmark page (checked October 24, 2026; it was 5.2% from March 31, 2024 to July 29, 2025), or set your own from five factors: your state's average veteran share of the civilian labor force over 3 years, veterans in the state employment service system over the last 4 quarters, your prior-year applicant and hiring ratios, your recent outreach assessments, and any other relevant factors. Document the benchmark, and the factors and weights if you use them, and keep it for 3 years. The benchmark is not a quota, ceiling or floor.

Worked example (sample company, labelled as a sample). In its last plan year a 300-employee contractor posted 62 openings and filled 60. It had 1,200 applicants, 84 of whom self-identified as protected veterans, and hired 4 of them.

MeasureCalculationResult
Protected veteran applicant ratio84 / 1,2007.0%
Protected veteran hiring ratio4 / 60 total hires6.7%
National benchmarkOFCCP5.1%
Hiring ratio vs benchmark6.7% vs 5.1%At or above benchmark

A result below the benchmark is not a violation in itself. It is a signal to look harder at your outreach assessment and personnel processes and to document what you will change. The kit's workbook builds this table from your requisition and applicant logs and keeps three years side by side, as the outreach assessment requires.

09

Annual VEVRAA and Section 503 compliance calendar

MonthTasks (calendar-year plan)
JanuaryUpdate both AAPs for the new plan year; top U.S. executive signs policy statements and they are reposted; set the VEVRAA hiring benchmark; close last year's (k) data and outreach assessment
FebruarySend vendor and subcontractor notices; confirm state job bank listings are flowing
MarchTrain recruiters, hiring managers and supervisors; review personnel processes and ICT accessibility
AprilQuarterly check of applicants, hires and listing timeliness; review open accommodation requests
MayReview physical and mental qualification standards due this half; plan outreach events
JuneMid-year audit and reporting review; update roster job categories and veteran status
JulyPick your VETS-4212 ending date (end of a pay period between July 1 and August 31); quarterly (k) data check
AugustVETS-4212 filing opens August 1; prepare counts for each hiring location; pull maximum and minimum headcount
SeptemberFile VETS-4212 by September 30; save the confirmation in the AAP file
OctoberQuarterly check; look for rule changes and a new national benchmark
NovemberDraft next year's outreach plan; review training completion
DecemberYear-end outreach effectiveness assessment; finish (k) data and benchmark comparison; purge records past retention unless a hold applies

A new covered contract also starts a 120-day clock to have a plan in place. Shift the months if your plan year starts on another date.

10

VETS-4212: the annual veterans report

Covered contractors file the VETS-4212 with the Department of Labor's Veterans' Employment and Training Service between August 1 and September 30 each year that follows a calendar year in which they held a covered contract, one report per hiring location (VETS-4212 page; 41 CFR part 61-300). VETS states the reporting threshold as $200,000.

  • Total employees by job category and hiring location, and how many are protected veterans
  • New hires in the 12-month period, and how many are protected veterans
  • Maximum and minimum number of employees at each hiring location during the period

The period is the 12 months before an ending date you choose at the end of a pay period between July 1 and August 31 (or December 31 with prior EEOC approval for the EEO-1). Veteran status can come from self-identification, voluntary disclosure or actual knowledge (61-300.10(e)). Reports can be filed online, by batch upload (encouraged for more than 10 hiring locations) or on paper.

11

Common VEVRAA and Section 503 mistakes

Still collecting disability self-ID on Form CC-305 after September 21, 2026 without legal advice
Dropping VEVRAA self-ID, data collection or the benchmark because the Section 503 versions were removed
Deleting the Section 503 plan altogether; the written plan is still required at 50 employees and $50,000
Posting openings with the state job bank after other recruitment instead of at least at the same time
No written outreach assessment, or one that does not use three years of (k) data
Treating the 5.1% benchmark as a quota, or not documenting which benchmark was adopted
Missing the September 30 VETS-4212 deadline or not filing a report for each hiring location
Using an old template that still cites E.O. 11246 job groups or the $150,000 threshold

12

What is inside

  • VEVRAA AAP template (Word)

    Sixteen sections in the order of 60-300.44, each with a guidance box, sample wording with gold placeholders, tables for process reviews, outreach assessment, data collection and the hiring benchmark, and signature blocks.

  • Section 503 AAP template (Word)

    Rewritten for the 9/21/2026 rule. Covers policy, personnel processes and ICT accessibility, qualifications, an accommodation procedure, outreach, audit and reporting with objectives, training and voluntary programs.

  • AAP data workbook

    Requisitions, applicants and self-ID logs feed a 3-year data collection analysis and a benchmark comparison. Outreach, accommodation and qualification review logs, an annual checklist and VETS-4212 counts by job category.

  • Guide, calendar and audit checklist

    A 7-page PDF on who needs which plan, each required element, the 2026 changes, a month-by-month calendar and an audit-ready checklist for both plans.

13

How to use it

Confirm coverage

Check contract values and headcount for each establishment, then enter your plan years and locations on the workbook Setup tab.

Log as you go

Record openings, applicants, self-ID invitations, outreach and accommodation requests through the year.

Write the plans

Fill the gold placeholders in both Word templates, paste in the workbook figures and delete the guidance boxes.

Review every year

Assess outreach, set the benchmark, work the checklist and file the VETS-4212 between August 1 and September 30.

14

Related templates and checklists

Browse all kits on the compliance templates and record kits page. HR teams building their hiring process alongside the AAP may also want our hiring checklist and new hire onboarding checklist, where you can add the post-offer self-ID invitation as a step. For year-round paperwork in other sectors, see the NSPIRE inspection checklist.

15

VEVRAA and Section 503 AAP questions

What is VEVRAA?
The Vietnam Era Veterans' Readjustment Assistance Act of 1974. It bars federal contractors and subcontractors from discriminating against protected veterans and requires affirmative action to employ and advance them. OFCCP enforces it under 41 CFR part 60-300.
Who needs a VEVRAA affirmative action plan?
A federal contractor or subcontractor with 50 or more employees and a contract of $200,000 or more needs a written VEVRAA AAP for each establishment, prepared within 120 days of the contract starting and updated every year (41 CFR 60-300.40).
What is the current VEVRAA hiring benchmark?
The national benchmark published by OFCCP is 5.1%, effective July 30, 2025, according to the DOL benchmark page checked October 24, 2026. You can adopt it or set your own from five factors. It is a yardstick, not a quota. Check the DOL page each year.
Is the Section 503 7% utilization goal still required?
No. The final rule effective 9/21/2026 rescinded the utilization goal and analysis, the disability self-identification invitations and the data collection analysis. The written Section 503 AAP and its other elements still apply.
Do we still need to invite applicants to self-identify as protected veterans?
Yes. VEVRAA still requires a pre-offer invitation and a post-offer invitation for the specific veteran categories, kept confidential (41 CFR 60-300.42). The kit includes a log to track both.
When is the VETS-4212 report due?
File between August 1 and September 30 each year, one report per hiring location, covering the 12 months before an ending date you choose between July 1 and August 31.
What happened to Executive Order 11246 affirmative action plans?
Executive Order 11246 was revoked on 1/21/2025 and the rule rescinding its regulations is effective 10/26/2026. VEVRAA and Section 503 plans are separate obligations that remain in effect.
Is there a free affirmative action plan template?
The regulations include an acceptable veteran self-ID invitation (Appendix B to 41 CFR part 60-300), but no complete plan template. Our free sample is the annual compliance calendar; the paid kit has the two editable Word AAP templates and the data workbook.
Does this kit make our plan compliant?
No template can guarantee that. The kit helps you prepare and maintain both plans and the supporting records. Have employment counsel or a compliance professional review your finished plans.

16

Important

This kit is a set of templates and record-keeping tools, not legal advice. Rules change: check the current text of 41 CFR parts 60-300, 60-741 and 61-300 and the OFCCP and VETS websites before you finalize a plan, and have a qualified employment lawyer or compliance adviser review your completed documents. Rules in this kit were checked on 10/24/2026. Greenwolf Tech Labs is not a law firm and is not affiliated with or endorsed by the U.S. Department of Labor, OFCCP or VETS.

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