Affirmative Action Compliance Specialist (OFCCP) Job Description

An Affirmative Action Compliance Specialist (OFCCP) keeps an employer's federal contract obligations toward people with disabilities and protected veterans in order. The title still says affirmative action because the two laws OFCCP enforces for this work, Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA), both require a written affirmative action program. What the title no longer covers is race and sex. On January 21, 2025, Executive Order 14173 revoked Executive Order 11246, and OFCCP's final rule rescinding the implementing regulations for Executive Order 11246 took effect on October 26, 2026. The placement goals, job group analyses and minority and female utilization tables that once filled an annual plan are gone from the federal framework.

Two programs, one owner

In the public sector, the person in this seat works for an institution that takes federal contract money, such as a state university with research and service contracts, an academic medical center, a public utility or authority that sells to a federal agency. The Section 503 regulations require a contractor with 50 or more employees and a federal contract or subcontract of $50,000 or more to develop and maintain an affirmative action program, prepared within 120 days of the start of the contract at each establishment. VEVRAA sets its own coverage threshold and requires a parallel program for protected veterans.

The disability program is mostly process. The specialist keeps a schedule for reviewing the physical and mental qualification standards in job descriptions, tests whether personnel processes give applicants and employees with disabilities careful, thorough consideration, and runs the accommodation process with HR and hiring managers. The veterans program carries the numbers. Applicants are invited to self-identify as protected veterans before an offer and again after one, and each year the specialist documents the counts the regulation lists, from veteran applicants and hires to total openings and jobs filled.

The calendar

Both programs must be reviewed and updated annually by the official the contractor designates, and both require an audit and reporting system that measures whether the commitments in the program are actually being carried out. Around that cycle sit the recurring tasks: listing openings with the state employment service, documenting outreach to disability and veteran organizations, posting the required notices in accessible formats, updating the equal opportunity clause language that flows down to subcontractors, and training recruiters and managers on what the two laws require of them.

Who they work with

The specialist sits between HR operations, legal counsel, the disability services or ADA office, veteran resource staff and the sponsored programs or procurement team that tracks which contracts trigger coverage. When the question is whether a new contract or a campus affiliate changes the institution's obligations, this is the person who reads the contract clause and answers it. The job is part analyst, part policy writer and part internal auditor, and the deliverable each year is a program document that would hold up if OFCCP asked to see it.

Education

A bachelor's degree is the usual entry point, typically in human resources, public administration, business, political science or a social science with a statistics component. O*NET's education data for equal opportunity representatives and officers, the occupation this job falls under, shows 66% of respondents saying a new hire needs a bachelor's degree. A master's in HR, public administration or labor relations can help for director-level offices at large universities and health systems, but it is not a precondition for the specialist level.

Experience

As a rough guide, specialists bring two to five years in HR compliance, recruiting operations, HRIS reporting or an EEO office before owning the affirmative action programs outright. Experience that transfers well includes running applicant-tracking reports, administering accommodation requests, and drafting policy that has to survive legal review. People who built race and sex affirmative action plans before 2025 already know the regulatory format, the annual cycle and the audit mindset; what they need now is depth in disability law and VEVRAA's protected veteran rules rather than in availability statistics.

Knowledge the job requires

• 41 CFR Part 60-741 (Section 503): the affirmative action program contents, personnel process review, the schedule for reviewing physical and mental qualification standards, accommodation, and the audit and reporting system.
• 41 CFR Part 60-300 (VEVRAA): protected veteran categories, pre-offer and post-offer self-identification, the hiring benchmark, data collection analysis and mandatory job listing.
• 41 CFR Part 61-300: the VETS-4212 report administered by the Labor Department.
• The ADA and its accommodation case law, since the interactive process works the same way whether the employer is a contractor or not.

Tools

O*NET's list of software for this occupation includes analytical tools such as Equitas EEOStat and PeopleClick PayStat and compliance software such as Bashen EEOSoft, alongside database and document management tools. In practice the specialist also lives in the employer's HRIS and applicant-tracking system, pulling requisition, applicant and hire data, and in a spreadsheet or statistics package for the veteran counts.

Credentials

No license is required. Credentials that fit the work:

• Equal Employment Opportunity Professional (EEOP) program, American Association for Access, Equity and Diversity (AAAED): AAAED's program, formerly known as the Certified Affirmative Action Professional (CAAP), provides 48 hours of instruction in three areas, including developing and implementing an affirmative action program.
• SHRM Certified Professional (SHRM-CP), Society for Human Resource Management: a general HR certification for HR professionals working at the operational level.
• Professional in Human Resources (PHR), HR Certification Institute (HRCI): an HR credential that validates technical and operational HR knowledge, including U.S. laws and regulations.

Traits that matter

Patience with regulatory text, a habit of documenting decisions on the day they are made, and the judgment to tell a hiring manager no without making an enemy of them. Plain writing matters here: the program document, the training slides and the accommodation letters all get read by people who are not compliance professionals.

A smaller rulebook after the 2026 rules

On August 21, 2026, the Labor Department published three OFCCP final rules. Beyond the Executive Order 11246 rescission, the Section 503 rule took effect on September 21, 2026, and rescinded three disability requirements: the regulation that required contractors to ask applicants and employees to identify their disability status, the related data collection requirements at 41 CFR 60-741.44(k), and the utilization requirements at 41 CFR 60-741.45, which included the 7 percent utilization goal set in the 2013 rule. The rule kept the equal employment opportunity clause, the outreach requirements in Subpart C, recordkeeping, complaint procedures and the audit and reporting system. It also set a December 21, 2026 effective date for its amendment to the administrative enforcement procedures at 41 CFR part 60-30.

The VEVRAA rule, effective the same day, removed the regulations' cross-references to Executive Order 11246 and updated jurisdictional thresholds: the VEVRAA coverage threshold increased from $150,000 to $200,000 effective October 1, 2025, and contracts and subcontracts of $200,000 or more are covered. For a specialist, that means checking which contracts still trigger VEVRAA coverage and which fall below it.

An agency with far fewer people

The enforcement side changed too. A GAO report published September 29, 2026 found that OFCCP had 484 full-time employees, or equivalent, in the first quarter of fiscal 2025, which dropped to 351 in the fourth quarter of fiscal 2025 and then to 79 in the first quarter of 2026. GAO also reported that DOL had suspended two key Section 503 monitoring tools: contractors' certification of their annual affirmative action programs, and audits. As of November 10, 2026, OFCCP's own home page says the Section 503 and VEVRAA AAP certification period will remain closed while the agency revises its processes and systems, and that Section 503 and VEVRAA, along with their implementing regulations, remain in effect.

GAO reported that in the fiscal 2025 selection process OFCCP identified about 320,000 contracts covered by Section 503, held by about 70,000 contractors. GAO made eight recommendations, including that DOL resume compliance audits and conduct strategic workforce planning for OFCCP. GAO also heard from some contractor representatives that the prospect of OFCCP audits helped focus their leadership's attention on Section 503 compliance. With audits not resumed as of May 2026, the specialist may have to make that internal case without them.

One carve-out applies to health care providers. OFCCP renewed its enforcement moratorium for providers in the Veterans Affairs health benefits program, and OFCCP's page says the moratorium will remain in effect until May 7, 2027. It exempts those providers from enforcement of their affirmative obligations under Section 503 and VEVRAA but not from their nondiscrimination obligations or complaint investigations.

Openings and paths

O*NET projects about 32,700 openings a year on average for compliance officers from 2025 to 2035, a figure for the whole occupation that includes every kind of compliance role. BLS does not project affirmative action compliance specialists separately. Within public institutions, the job can sit inside a broader equal opportunity or institutional compliance office, and next steps can include director of equal opportunity, ADA coordinator, Title IX or civil rights compliance roles, or HR compliance management. A record of working accommodation programs and clean veteran data is the evidence to bring to those interviews.

Dear Search Committee,

Please consider me for the affirmative action compliance opening in your Office of Equal Opportunity. For the past four years I have worked in the HR compliance unit of a regional public university that holds federal research and service contracts, and since the federal rules changed I have rebuilt our programs around the obligations that remain.

When our race and sex plan was retired, I proposed that we not simply delete it but move the staff time into the Section 503 and VEVRAA programs, which had always been treated as appendices. I rewrote the disability program from the regulation up, set a review schedule for physical and mental qualification standards across our staff job descriptions, and worked with our disability resources office to move accommodation requests into one tracked queue with a documented interactive process.

On the veterans side, I own the self-identification invitations, the annual data collection analysis, the hiring benchmark and our VETS-4212 filing. I found that two campus job boards were not feeding openings to the state employment service and fixed the integration with our applicant-tracking vendor, then added a monthly spot check so the problem would not come back quietly.

I also run the training that recruiters and search committee chairs take each fall. I rebuilt it around the questions they actually ask me, such as what to do when a candidate requests an alternative format for an interview exercise, and attendance went from grudging to voluntary.

I would welcome the chance to bring the same approach to your office: read the regulation closely, write the program plainly, and keep the documentation current every month rather than every audit.

Sincerely, Jordan Ellison