If you hold a covered federal contract, OFCCP expects one small thing every year. You have to set a VEVRAA hiring benchmark. Then you have to write it down. Most contractors get the first part right. They miss the second part.

The rule is short. You "shall document the hiring benchmark" you set each year. That comes straight from 41 CFR 60-300.45(c). It sounds simple. But a missing benchmark record is an easy audit finding. A compliance officer can write it up in seconds. There is no judgment call. Either you have the paper or you do not.

This guide walks through the yearly task. Who has to do it. The two ways to set the number. What to keep on file for each one. And how long to hold it. We will keep it practical. The goal is a clean record you can hand over without scrambling.

What does the VEVRAA benchmark documentation rule require?

The benchmark is a yearly target. It is the share of your new hires you aim to be protected veterans. It is not a quota. You do not get fined for missing it. But you do have to set one, measure against it, and document the number you chose.

The documentation duty sits in 41 CFR 60-300.45. Subsection (c) is the line that matters. It says you "shall document the hiring benchmark" you set each year. If you build your own number, you also document how you built it.

So there are really two pieces of paper. First, the benchmark itself. The percent you picked for the year. Second, the support behind it. Either a note that you adopted the national figure, or the data you used to build your own.

That is the whole ask. Set it. Write it down. Keep it. The reason it trips people up is that it is easy to skip in a busy year. Nobody reminds you. Then an audit notice shows up and the record is not there.

Who has to document a benchmark?

This applies to covered federal contractors and subcontractors. The trigger is a dollar threshold plus a headcount. If you clear both, you owe a written affirmative action program. The benchmark record is part of it.

The coverage line moved in late 2025. VEVRAA affirmative action obligations now start at a single contract of $200,000 or more. The old line was $150,000. That change took effect October 1, 2025. The written program duty applies once you also have at least 50 employees.

There is a separate number that confuses people. VETS-4212 reporting still starts at $150,000. That is a DOL VETS rule, not OFCCP. So you can owe the annual veteran report before you owe a full affirmative action program. Two different agencies. Two different dollar lines.

Both numbers shift over time for inflation. The FAR Council adjusts them. Check the current thresholds on dol.gov before you decide you are not covered. Guessing here is risky.

National benchmark or build your own?

OFCCP gives you two ways to set the number. You pick one each year. Both are valid. The choice drives what you document.

The first way is the national benchmark. OFCCP publishes a single percent. You adopt it. As of July 30, 2025, that figure is 5.1%. It dropped from 5.2%. The number changes most years, so do not hard-code it. You can read the current one on the OFCCP hiring benchmark page.

The second way is the five-factor method. You build your own number using your local data. This takes more work. But it can give you a target that fits your real labor market. If your area has a high veteran population, your own number may differ from the national one.

Most contractors take the national figure. It is faster and the paper trail is tiny. The five-factor method fits when you want a number that reflects your region. It also fits when you are pushing a stronger veteran hiring story. There is no wrong choice. There is only the wrong record.

What do you document if you use the national benchmark?

This is the easy path. You adopted the figure OFCCP published. So your record just has to show that.

Write down the percent you used for the year. Write down the date you set it. Note that you adopted the national benchmark. Keep a copy or screenshot of the OFCCP page showing that figure. That is it.

Keep it inside your affirmative action program file for the year. Tie it to your program date. If your program runs from a set date each year, your benchmark record should match that cycle. One number, one date, one source note.

The mistake here is treating it as too small to bother with. People assume "everyone knows the national number, so why write it down." OFCCP does not work that way. If it is not in your file, it did not happen. A two-line memo with a saved screenshot closes the whole task.

What do you document with the five-factor method?

This path needs more on file. You built your own number. So you have to show your math. The rule says you document each of the five factors and how much weight you gave each one.

The five factors come from OFCCP's regulation. In plain terms, they are the data points you weigh to land on your own target.

For each factor, write down the data you used and the source. Then write down how heavily you leaned on it. The final number should fall out of that work. A compliance officer should be able to follow your logic without a phone call.

Save the source files too. The state veteran data. Your prior-year hiring counts. The outreach results. If your number gets challenged, those backups are your defense. A bare percent with no math behind it is a weak record.

How long do you keep the benchmark record?

The benchmark documentation falls under the three-year keep rule. The records tied to 60-300.45(c) are held for three years from the date you create them. So this year's benchmark memo stays on file for three years.

Other VEVRAA records have a shorter clock. Under 41 CFR 60-300.80, general personnel records run two years for larger contractors. The smallest contractors keep them one year. But the benchmark support sits in the longer three-year bucket. When in doubt, keep it longer, not shorter.

One more rule overrides all of this. If you get an audit notice or a complaint, you freeze everything. You hold the records until the matter is fully closed. Do not let a normal retention clock delete something while OFCCP is looking at you.

What does a simple yearly workflow look like?

You do not need a big process for this. You need a repeatable one. Tie it to the date your affirmative action program starts each year. Then run the same four steps.

That last step is where the benchmark stops being busywork. You set a number so you can measure your veteran hiring against it. If you fall short, that is a signal. It means you should step up outreach. We cover that recovery side in our guide on what to do when you miss the veteran hiring benchmark.

One tip on consistency. Use the same memo template every year. Same headings, same fields, same order. Then a reviewer can find what they need fast. It also makes the task quick for whoever owns it. They are not reinventing the format each cycle. A clean, repeated record reads as a contractor who takes the rule seriously.

It also helps to compare your number to your peers. If your veteran hire rate trails firms like yours, that is worth knowing before an audit does. We walk through that in our guide on how to benchmark veteran hiring against peers.

For the why behind the number itself, our VEVRAA hiring benchmark explainer breaks down why it keeps changing. Want the full compliance picture? Start with our overview of VEVRAA compliance for federal contractors. And for the tracking side of the number, see what data contractors actually track against the OFCCP benchmark.

How does the benchmark connect to real outreach?

The number on paper is half the job. The other half is doing the outreach that backs it up. OFCCP looks at whether you made a real effort to find and hire veterans. A percent in a file alone does not prove that.

That means keeping good outreach records all year. Where you posted. Who you partnered with. What came back. Our guide on building OFCCP good-faith-effort outreach records covers that paper trail in detail. You can also host a SkillBridge program as documented outreach. We cover that in our piece on SkillBridge as documented veteran outreach.

The hard part for most contractors is the supply side. You can document a benchmark all day. But you still need real veteran candidates coming through the door. That is the gap a steady talent pipeline fills.

This is where Best Military Resume fits. We are a veteran talent platform with a fresh, growing pool. We add over 1,000 new profiles every month. We have also helped build 60,000 resumes. That is a steady stream of transitioning service members and veterans you can reach directly. It is exactly the kind of sustained outreach the benchmark is meant to drive.

For a midsize contractor, this matters most. You likely do not run a big in-house veteran hiring team. You still owe the same records as a large firm. A ready pool lets you show real outreach without building a whole program from scratch. You document the benchmark, then point to a live source of veteran candidates behind it.

Document the benchmark every year. Keep the record for three years. And keep a real pipeline of veteran candidates so the number reflects actual hiring, not a paper exercise. If you want access to that pipeline, you can reach out to access BMR's veteran talent pool.