top of page

Disability Self-Identification Has Changed: What the New Section 503 Rules Mean for Job Seekers

2 days ago
7 min read

For years, many job seekers with disabilities applying for jobs with federal contractors encountered a familiar question during the application process: Do you voluntarily identify as a person with a disability?


That question was tied to Form CC-305, the Voluntary Self-Identification of Disability Form, and federal contractors’ responsibilities under Section 503 of the Rehabilitation Act.



The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has discontinued Form CC-305 and eliminated the requirement for federal contractors to invite applicants and employees to voluntarily self-identify their disability status through the form.


For job seekers and employees with disabilities, the change may raise a new set of questions:

  • Should I still tell an employer I have a disability?

  • Why am I still being asked to voluntarily self-identify as a protected veteran?

  • What happens if I need an accommodation?

  • And what do these changes mean for disability inclusion in the workplace?


Here is what people with disabilities should know.


Diverse coworkers in a bright glass conference room listen as a man raises his hand during a business meeting.


What changed under Section 503?


Section 503 of the Rehabilitation Act applies to covered federal contractors and subcontractors and prohibits employment discrimination against qualified individuals with disabilities.


For more than a decade, the regulations also required covered contractors to invite applicants and employees to voluntarily self-identify as having a disability using Form CC-305.


Form section with three unchecked boxes under "Please check one of the boxes below", asking about disability status.

Employers used that information in their disability affirmative action programs and to evaluate representation against OFCCP’s 7% utilization goal.


The 2026 changes reshape that framework. Beginning September 21, 2026:

  • The requirement to invite applicants and employees to voluntarily self-identify using Form CC-305 was eliminated.

  • Form CC-305 was discontinued.

  • Related disability applicant and hire data-collection requirements were eliminated.

  • The 7% disability utilization goal and associated analysis were eliminated.


These changes significantly affect how federal contractors collect and measure disability representation.


They also make it especially important for applicants to understand the difference between disability self-identification, protected veteran self-identification, disability disclosure, and requesting an accommodation.


Veterans may still be asked to self-identify


Job seekers may still encounter voluntary self-identification questions during the application process, particularly questions about protected veteran status.


The Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) has separate requirements for covered federal contractors and subcontractors. VEVRAA provides employment protections for certain categories of protected veterans and includes its own affirmative action and voluntary self-identification requirements.


Protected veteran categories include:

  • Disabled veterans

  • Recently separated veterans

  • Active-duty wartime or campaign badge veterans

  • Armed Forces service medal veterans


This creates an important distinction for applicants.


Disability self-identification: The Section 503 requirement for federal contractors to invite applicants and employees to self-identify using Form CC-305 has been eliminated.


Protected veteran self-identification: Covered federal contractors may still ask applicants and employees to voluntarily identify their protected veteran status under VEVRAA.


Disabled veterans: A person can be both an individual with a disability and a protected veteran. A disabled veteran may still encounter a protected-veteran self-identification question even though the former Section 503 disability self-ID requirement has changed.


That distinction is especially important right now. Someone may hear that federal disability self-identification requirements have been eliminated and then encounter a voluntary protected veteran question during an application.


Section 503 and VEVRAA are separate federal requirements covering different forms of self-identification. The changes to Section 503 do not eliminate VEVRAA’s protected-veteran requirements.


Understanding which question you are being asked, and why, can help you make a more informed decision when completing an application.



Self-identification and disability disclosure serve different purposes


Historically, completing Form CC-305 was a voluntary self-identification. This typically happens through forms included in job applications, onboarding paperwork, or internal HR systems, a process used for federal contractor compliance and workforce measurement.


Disclosing a disability directly to an employer can serve a different purpose.


A person may choose to disclose a disability when they need a reasonable accommodation during the hiring process or at work. Someone may also choose to share their disability in a conversation with a manager, HR representative, disability employee resource group, or other workplace resource.


Those decisions are personal and situation-specific.


The elimination of the Form CC-305 requirement changes the federal contractor self-ID process. People with disabilities still have workplace protections under Section 503, including protection against employment discrimination for qualified individuals with disabilities who work for or apply to covered federal contractors.



Do I have to disclose my disability when applying for a job?


For many people with non-apparent disabilities, deciding when, how, or whether to disclose can be one of the more complicated parts of navigating employment.

There is no universal answer.


Your decision may depend on whether you need an accommodation, how your disability affects the hiring process or your work, your comfort level, and the circumstances surrounding the role.


A useful place to begin is by asking yourself:

  • Do I need an accommodation to complete the application or interview?

  • Will I need an accommodation to perform the job?

  • Who needs information about my disability?

  • What information is relevant to the accommodation I am requesting?

  • At what point in the process would sharing this information help me?

  • What would make me feel comfortable having this conversation?


The removal of Form CC-305 makes understanding these distinctions even more important.

A standardized federal disability self-ID form previously created a familiar point in the hiring process where applicants could report disability status. Applicants may now encounter a different combination of voluntary demographic questions depending on the employer.


For veterans, this can still include a request to voluntarily self-identify as a protected veteran under VEVRAA.



What if I need a reasonable accommodation?


The Section 503 changes do not eliminate an applicant’s ability to request a reasonable accommodation.


Accommodations during hiring could include:

  • Additional time or an accessible format for an assessment

  • A sign language interpreter

  • Captioning

  • An accessible interview location

  • Adjustments to an interview or testing process

  • Assistive technology compatibility

  • An alternative to an inaccessible digital or AI-enabled hiring tool

  • Another change that provides equitable access to the hiring process


In the workplace, accommodations can include changes to equipment, schedules, communication methods, workplace environments, technology, or how certain job functions are performed.


If an employer provides an accommodation process, follow the instructions provided with the application or on the employer’s careers site.


This is becoming especially important as employers introduce more technology and artificial intelligence into recruiting. If an online application, assessment, video interview, AI interview, chatbot, or other hiring technology creates an accessibility barrier, applicants can contact the employer to ask about an accommodation or accessible alternative.



What do these changes mean for employers?


The policy change creates an important question for employers:

How will your organization know whether its recruiting and workplace practices reach and support people with disabilities when the previous federal self-ID and utilization framework is no longer required?


People with disabilities remain part of the workforce.


Employers still need effective ways to identify accessibility barriers, evaluate candidate and employee experiences, provide accommodations, reach disability talent, and understand where people with disabilities may encounter barriers throughout the employment lifecycle.


That work can include:

  • Testing the accessibility of career sites and application systems

  • Evaluating accessibility within assessments and AI-enabled hiring technology

  • Creating a clear and accessible accommodation request process

  • Training recruiters and hiring managers on disability inclusion

  • Building relationships with disability-focused talent and community organizations

  • Gathering candidate and employee feedback

  • Reviewing hiring and advancement processes for potential barriers

  • Supporting disability-focused employee resource groups and other internal communities


The Section 503 changes give employers a reason to examine how they define and measure progress in disability inclusion.


Disability inclusion goes beyond a form


For years, Form CC-305 and the 7% utilization goal gave many federal contractors a defined mechanism for collecting disability data and evaluating representation.


With that framework changing, employers have an opportunity to look more broadly at the experiences behind the numbers.


  • Are candidates with disabilities finding the organization?

  • Can they access the career site and application?

  • Can someone who uses assistive technology complete an assessment?

  • Are candidates clearly told how to request an accommodation?

  • Are recruiters prepared to respond when someone discloses a disability?

  • Can employees access accommodations effectively once they are hired?

  • Do people with disabilities have opportunities to develop and advance?


These questions can provide a much fuller picture of disability inclusion across the employee lifecycle.



For job seekers, focus on what helps you succeed


The changing regulatory environment adds another layer to an already complex job market.


Your disability is one part of the experience, skills, knowledge, and perspective you bring to work.


As you pursue opportunities, focus on the information and support you need to participate fully in the hiring process and succeed in the role.


Research an employer’s accessibility and accommodation practices. Pay attention to how the employer communicates accommodations throughout the application process. Ask for an accommodation when you need one. Understand the purpose of voluntary self-identification questions you encounter. Decide when sharing disability-related information makes sense for your individual circumstances.


Your approach can change from one employer or opportunity to another.



What comes next for disability inclusion?


The 2026 Section 503 changes mark a significant shift in how federal contractors approach disability data and affirmative action.


For employers, this is a moment to strengthen the systems and practices that create access throughout recruiting, hiring, advancement, and retention.


For job seekers with disabilities, understanding the difference between self-identification, disclosure, protected veteran status, and requesting an accommodation can make the changing landscape easier to navigate.


For veterans with disabilities, understanding the distinction between Section 503 and VEVRAA is particularly important. You may continue to encounter protected-veteran self-identification questions as part of the hiring process even as disability self-identification requirements change.


At Disability Solutions, we believe progress in disability employment comes from accessible hiring experiences, meaningful connections to disability talent, effective accommodations, and workplaces designed so people with disabilities can contribute and grow.


Policies and reporting structures will continue to evolve. Access, opportunity, and informed choice remain essential to an inclusive employment experience.


For job seekers


Navigating today’s job market with a disability? Explore our Job Market Guide for People with Disabilities for practical strategies for applications, accessibility, AI in hiring, networking, and finding the right opportunities. And visit our career resources for expert guidance, job search tools, accessibility help, and career development and support, all in one place.


For employers


The Section 503 landscape has changed. Disability Solutions can help you strengthen your disability talent strategy and build more inclusive experiences for candidates and employees.



Recent Posts

bottom of page