How to Document the VEVRAA Benchmark Every Year
Hire veterans who are ready for the job
We turn real military records into clear, civilian resumes so your hiring team can see what each veteran actually did.
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.
This is not legal advice
Figures and thresholds change. Confirm the current benchmark and dollar limits on dol.gov before you file. When in doubt, run it past your OFCCP counsel.
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.
Key Takeaway
The benchmark is not a quota you must hit. It is a number you must set, measure against, and keep a record of. The record is the part OFCCP checks.
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.
- •Single contract of $200,000 or more
- •At least 50 employees
- •Enforced by OFCCP
- •This is where the benchmark record lives
- •Contract of $150,000 or more
- •Filed once a year
- •Enforced by DOL VETS
- •Separate from the benchmark task
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.
The Five Factors You Must Document
Veteran share of the local workforce
State-level data on veterans in your civilian labor force.
Employment service data
Veterans who came through the state job service system.
Your own prior-year applicant and hire ratios
How many veterans applied and how many you hired last year.
How well your outreach is working
An honest read on whether your veteran recruiting moved the needle.
Any other factor that fits your business
Other relevant context you used to land on the number.
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.
Do not delete during an audit
If an audit or complaint is open, retention clocks stop. Hold every related record until the matter is fully closed, even if the normal period has passed.
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.
Pick your method
National benchmark or five-factor. Most contractors take the national figure.
Set the number and date it
Confirm the current national figure on dol.gov, or run your five-factor math.
Write the record and save sources
A short memo with the percent, the date, the method, and any backup data.
Measure against it and file it
Compare your veteran hire rate to the benchmark, then keep it for three years.
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.
"A benchmark on paper means nothing if you have no veterans coming through the door. Set the number, document it, then go find the people to hit 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.
Frequently Asked Questions
QDo I have to document the VEVRAA benchmark if I take the national number?
QWhat is the current VEVRAA hiring benchmark?
QIs the VEVRAA benchmark a quota I have to hit?
QHow long do I keep the benchmark documentation?
QWhat is the difference between the national benchmark and the five-factor method?
QAt what contract value does VEVRAA affirmative action apply?
QWhere can I find veteran candidates to back up my benchmark?
About the Author
Brad Tachi is the CEO and founder of Best Military Resume and a 2025 Military Friendly Vetrepreneur of the Year award recipient for overseas excellence. A former U.S. Navy Diver with over 20 years of combined military, private sector, and federal government experience, Brad brings unparalleled expertise to help veterans and military service members successfully transition to rewarding civilian careers. Having personally navigated the military-to-civilian transition, Brad deeply understands the challenges veterans face and specializes in translating military experience into compelling resumes that capture the attention of civilian employers. Through Best Military Resume, Brad has helped thousands of service members land their dream jobs by providing expert resume writing, career coaching, and job search strategies tailored specifically for the veteran community.
Found this helpful? Share it: