Form CC-305 retires: federal contractors must reset disability self-ID as Section 503 rule takes effect
Not legal advice. This article discusses legal and regulatory developments and is generated with AI assistance under human editorial review. It is provided for informational purposes only and does not constitute legal advice. Laws and regulations vary by jurisdiction and are subject to change. You should consult your own qualified legal counsel before taking or refraining from any action based on the content of this article. Read our AI Transparency statement.
The News
On 21 September 2026 the U.S. Department of Labor's Section 503 final rule took effect, formally discontinuing Form CC-305 — the Voluntary Self-Identification of Disability form federal contractors have used since 2013 — and rescinding the duty to invite applicants and employees to self-identify disability status, the related data-collection requirements, and the 7% utilisation goal. The rule, published in the Federal Register on 21 August, reasons that employer-initiated disability inquiries clash with the ADA's limits on pre-offer questions. With the form now retired, the Center for Workplace Compliance (CWC) on 22 September published a sample post-offer, pre-employment self-identification form for contractors that wish to keep collecting the data lawfully, warning that any future disability inquiry is now “governed squarely by the Americans with Disabilities Act” and the EEOC's rules.
Why It Matters
For TA leaders at federal contractors this is an immediate onboarding and ATS workflow change, not a future planning item. Any disability self-id prompt wired into your application or onboarding flow through CC-305 has to come out now. The compliance framing has flipped: collection is no longer required, and any continued collection must survive ADA scrutiny — post-offer, uniform across the job category, and confidential. The duties that did not move are non-discrimination, reasonable accommodation, and the Section 503 affirmative action plan itself. Contractors with state or local disability-reporting obligations (Minnesota, Wisconsin, Cincinnati, and others) still have to collect, now under added ADA risk.
Taking Action
All action is situated in your corporate context. These are starting points, not prescriptions — choose what fits.
Connect
Who to talk with in your enterprise
Talk to your HRIS or onboarding lead and your federal compliance (OFCCP) officer today: confirm every application and onboarding workflow that surfaces Form CC-305 is switched off, and that historical disability data is retained — segregated and confidential — for audits of prior periods, since the rule does not require purging old records.
Inspect
What to take a closer look at
Audit your ATS and onboarding modules for any active CC-305 disability self-identification field. Check whether your AAP vendor or compliance system still auto-generates the 7% utilisation analysis; it should stop for plan years beginning on or after 21 September. If you operate in Minnesota, Wisconsin, Cincinnati, Louisville, Madison, Saint Paul, or San Diego, confirm whether local disability-reporting duties still compel collection, and route any continued collection into the post-offer window.
Reflect
What to think about more deeply
The government just told federal contractors to stop asking applicants about disability. If your inclusion strategy leaned on a mandatory form to measure it, how do you prove progress on disabled hiring now that the data is voluntary — and entirely the candidate's to offer?