OFCCP Compliance Evaluation: What Happens, Phase by Phase
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.
An OFCCP scheduling letter lands in the mail. It has your company name on it. It has a due date. And it asks for a stack of records you may not have looked at all year.
This is a compliance evaluation. Most people call it an audit. It is the government checking whether you did the veteran hiring work the law asks for. It is not a lawsuit. No one filed a complaint against you. Your name came up on a list, and now the clock is running.
This guide walks the process phase by phase, on the veteran side. You will see what the scheduling letter starts. Then what veteran records OFCCP asks for. Then how the desk audit works, and when an on-site visit happens. If you hire on federal contracts, this is the process you want to understand before the letter shows up, not after.
What Is an OFCCP Compliance Evaluation?
OFCCP stands for the Office of Federal Contract Compliance Programs. It sits inside the U.S. Department of Labor. Its job is to check that federal contractors follow the equal employment laws tied to their contracts.
One of those laws is VEVRAA. That is the Vietnam Era Veterans' Readjustment Assistance Act, set in 38 U.S.C. 4212. VEVRAA asks covered contractors to take active steps to recruit and hire protected veterans. A compliance evaluation is how OFCCP checks that work.
The rules in 41 CFR 60-300.60 list a few kinds of evaluation. A full compliance review is the deep one. There are also lighter versions, like a compliance check or a focused review. Most contractors think of the full review, so that is the path this guide follows.
One note on the current climate. In 2025, an executive order revoked Executive Order 11246. That order covered race and sex based affirmative action. VEVRAA is different. It is a law passed by Congress, tied to the veteran side. It still applies to covered contractors. So the veteran obligations described here are still live.
Who is covered by VEVRAA?
As of October 1, 2025, the coverage floor for a written veteran plan rose. Now it takes a single federal contract of $200,000 or more, at a site with 50 or more employees. That figure went up from $150,000 for inflation.
How Does the Scheduling Letter Start the Audit?
The process starts with a scheduling letter. OFCCP mails it to a specific work site. Your site got picked from a neutral list, not because someone reported you.
The letter comes with an itemized listing. That is the shopping list of records OFCCP wants. It asks for your veteran plan and the data behind it. You usually get 30 days to send it in.
Thirty days sounds like plenty. It is not, if you are building the file from scratch. The contractors who breeze through this already had the records on hand. The ones who scramble are the ones who wrote the plan the week the letter came.
Want the contrast with the other way OFCCP can knock on your door? A complaint works very differently. A protected veteran files it, and it targets a specific action. We cover that path in the OFCCP veteran complaint investigation process. The scheduling letter here is the routine audit, not the reaction to one worker.
- •Starts with a scheduling letter
- •Your site was picked from a list
- •Reviews your whole veteran program
- •No worker had to report you
- •A protected veteran files it
- •Targets one action or decision
- •Focused on that person's claim
- •Reactive, not a routine check
What Veteran Records Does OFCCP Ask For?
The itemized listing asks for the pieces of your veteran program. On the veteran side, a few items carry the most weight. Here is what OFCCP wants to see.
First, your written veteran plan. That is the veteran section of your affirmative action program, built under 41 CFR 60-300.44. We break that document down in the veteran section of your VEVRAA plan.
Second, your hiring benchmark. Each year you set a number for veteran hiring. Most contractors use the national benchmark. OFCCP wants to see that you set it and wrote it down. See how to document the benchmark every year.
Third, your outreach records. This is where a lot of files fall apart. OFCCP does not just want a list of veteran job boards you signed up for. It wants proof that you looked at whether the outreach worked. That review is the part contractors skip.
Fourth, your applicant and hire data. You track how many people who applied and got hired self-identified as protected veterans. The data rules live in 60-300.44(k). This is the number OFCCP lines up against your benchmark.
Veteran items on the itemized listing
Written veteran plan
The veteran section of your affirmative action program
Annual hiring benchmark
The veteran hiring number you set and recorded
Outreach and its results
Sources you used plus your review of what worked
Applicant and hire data
Self-identified veteran counts, applied and hired
What Happens During the Desk Audit?
Once you send the records, the desk audit begins. This is the first real review phase. An OFCCP officer reads your file at their office. They do not visit your site yet.
In the desk audit, they check that the plan has all the parts it needs. They line up your veteran hire numbers against your benchmark. And they read your outreach records to see if you reviewed your own results.
This is why the outreach piece matters so much. When the file lands, OFCCP scores your outreach records, not your good intentions. We show how to build that file in OFCCP good-faith-effort outreach records.
Missing the benchmark by itself is not a violation. The benchmark is a target, not a quota. What OFCCP looks for is effort. Did you set the number? Did you reach out? Did you check if the reaching out worked? A weak outreach file hurts you more than a low hire count. Learn what the number means in the OFCCP veteran hiring benchmark contractors track.
Scheduling letter
OFCCP mails the letter and itemized listing. You send records, usually within 30 days.
Desk audit
An officer reads your plan and data off-site. They check parts, benchmark, and outreach.
On-site review
Only if the desk audit raises questions. OFCCP visits, reviews policies, and copies records.
Findings and close-out
OFCCP closes the case or works with you to fix any gaps it found.
When Does OFCCP Come On-Site?
Not every audit reaches your front door. Many close after the desk audit. The on-site review happens when the paper raises questions the officer cannot answer from the file.
If they do come, the on-site is deeper. They look at how your policies work in practice. They may review employment records and copy documents. They may talk to staff who run hiring.
After the on-site, OFCCP may do more analysis off-site. They line up what they saw against what your file claimed. Then they reach findings. If they find gaps, they usually work with you to fix them through a written agreement first. Enforcement is the last step, not the first.
One thing to know up front. You are asked to give OFCCP access to the records the rules cover. If a contractor blocks access or refuses to hand over records, that can speed up the process against them. Cooperation keeps you in the routine lane.
Do not stonewall the officer
Refusing access or withholding records can move a case toward enforcement faster. Sending clean records on time is the smoother path.
How Long Do You Have and What Is the Timeline?
The most fixed number in the whole process is the first one. You usually get 30 days from the scheduling letter to submit your records. That window is set by the itemized listing.
After that, the pace is less fixed. A desk audit can take weeks or months. It depends on how clean your file is and how busy the office is. A case with an on-site review takes longer than one that closes at the desk.
So the timeline you control is the front end. The cleaner the file you send in that first 30 days, the faster the rest tends to go. A messy submission draws follow-up questions, and each round adds time.
Do not wait for the letter to build the file. The records are things you keep all year. When the letter comes, you should be pulling from a file, not writing one.
How Long Must You Keep Veteran Records?
OFCCP can only check records that still exist. So the rules set how long you keep them. The retention periods live in 41 CFR 60-300.80.
Most contractors keep records for two years from the date of the record or the action. That two-year rule applies if you have 150 or more employees or a contract of at least $150,000. Smaller contractors below both marks keep records for one year.
There is one more rule that trumps the clock. If an audit or a complaint is open, you hold every record tied to it until the matter is fully closed. You do not clear the file mid-audit.
Key Takeaway
A compliance evaluation rewards the records you built before the letter arrived. The audit reads what you wrote down, not what you meant to do. Keep the file current all year.
How Do You Get Ready Before the Letter Comes?
The best prep is boring and steady. You keep the veteran program running when no one is watching. Then the audit is just handing over what you already have.
Start with the plan. Keep the veteran section of your affirmative action program current. Set the hiring benchmark each year and write it down. Track the veterans who apply and who get hired. And post your open jobs with the state job service, which we cover in the VEVRAA mandatory job listing rule.
The outreach records are the part to obsess over. Log every veteran source you use. Note who you reached, how many applied, and how many got hired. Then write a short review of what worked. That review is the thing weak files are missing.
Strong outreach needs real veteran candidate sources you can point to by name. That is where BMR fits. Our pool adds 1,000+ new profiles every month and has produced more than 65,000 resumes. Naming a live veteran talent source in your outreach file gives the officer something concrete to read.
1 Keep the plan current
2 Set and record the benchmark
3 Log outreach and results
4 Hold records long enough
What Should You Do Next?
A compliance evaluation is a paperwork test with a deadline. The contractors who pass it are the ones who kept a clean veteran file all year. The full picture of what the law asks sits in our VEVRAA compliance guide for federal contractors.
The strongest thing you can put in that file is real veteran hiring, backed by a real veteran source. That is what BMR gives you. You get a live pool of veteran candidates to recruit from, and a documented outreach source to name in your records.
If you want access to BMR's veteran talent pool, reach out through our hire page. If you run a hiring program and want a deeper setup, start at partner with us. Build the veteran pipeline now, so the file is ready when the letter comes.
Frequently Asked Questions
QWhat triggers an OFCCP compliance evaluation?
QHow long do you have to respond to the scheduling letter?
QWhat veteran records does OFCCP ask for?
QIs missing the veteran hiring benchmark a violation?
QWhich contractors are covered by VEVRAA?
QHow long must you keep VEVRAA records?
QDoes every compliance evaluation include an on-site visit?
QIs VEVRAA still enforced after the 2025 executive order?
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: