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EEO compliance: Keep track of current developments and what’s ahead

October 2026 employment law letter
Authors: 

Benjamin Banta and Martin J. Regimbal, The Kullman Firm

With the constantly changing equal employment opportunity (EEO) and affirmative action (AA) landscapes in recent years, it has been difficult for employers to stay on top of continuing obligations. Below is a list of what to be aware of over the coming months.

Developments with the U.S. Department of Labor (DOL)

VETS-4212 federal contractor portal now open. Federal contractors with contracts valued at $200,000 or more should file their VETS-4212 data by September 30, 2026. Although affirmative action plans (AAPs) for minorities and females were placed on the chopping block in January 2025 and there have been discussions of eliminating AAPs for individuals with disabilities and related disability reporting—as well as EEO-1 reporting (more on EEO-1 reporting below)—AAP commitments for protected veterans have been moving silently under the radar. 

That said, it’s now time for federal contractors that hold a contract valued at $200,000 or more to file their VETS-4212 data in the VETS-4212 federal contractor portal. The portal opened on August 1, 2026, and will remain open until September 30, 2026.

Final rule issued eliminating several data collection and reporting requirements applicable to individuals with disabilities, effect September 21, 2026. In alignment with Executive Order (EO) 14173 issued in January 2025 rescinding EO 11246, the DOL has issued a final rule that eliminates the following data collection and reporting requirements for federal contractors:

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