The Veteran Section of Your VEVRAA Affirmative Action Plan

You won a federal contract. Now the government wants a written affirmative action program. It shows how you recruit, hire, and keep protected veterans. This is where a lot of midsize employers freeze up. The rule sounds heavy. The veteran part feels vague. And a bad audit can cost real money.

The good news is that the rule spells out what belongs in the veteran section. All of it sits in one place. That place is 41 CFR Part 60-300. Once you see the parts, you can build each one.

This guide walks through every piece. What the policy statement says. How you review your hiring steps. What counts as real outreach. Where the hiring benchmark goes. How long you keep the records. By the end you will know what to put in each part. You will also know what proof to keep for an audit.

This is written for the HR or compliance person who has to build or update the plan. If you want the wider view first, start with our VEVRAA compliance guide for federal contractors. Then come back here for the veteran section itself.

Who Needs a Veteran Affirmative Action Plan?

VEVRAA covers federal contracts of $200,000 or more. That threshold rose from $150,000 on October 1, 2025. The written plan adds one more test. You need it if you have 50 or more employees and a $200,000 contract. That plan must include a veteran section.

Both numbers sit in 41 CFR 60-300.40. The dollar amount can change with inflation. Check the current figure with OFCCP before you decide you are exempt. When in doubt, build the plan.

The plan is about protected veterans, not every veteran. Protected veterans fall into four groups. Fuzzy on the four? Read what counts as a protected veteran before you write a word. The whole plan hangs on that definition.

What Belongs in the Veteran Section?

The required parts come from 41 CFR 60-300.44. The rule lists eleven parts by letter, (a) through (k). You do not get to pick and choose. Each part needs to show up in your written plan.

Here are seven core parts in plain words. Accommodation, harassment, internal sharing, and training make up the other four. We build each one below.

What Goes in the Policy Statement?

Start with a short written policy. It says you recruit, hire, train, and promote in all job titles without regard to protected veteran status. The rule calls for this policy statement first.

Keep it plain. Name protected veterans by that term. Say you take affirmative action to employ and advance them. Post it on company bulletin boards. Give disabled veterans an accessible version, such as large print.

The rule also wants the policy shared inside and outside the company. Inside, it goes in the handbook and to any union officials. Outside, it goes to your subcontractors and vendors in writing. This spreads the promise past your front door.

One more part fits here. The rule wants a named official who owns the plan. Pick one person. Give them real backing from senior leaders. Give them the staff and time to do the work. A plan with no owner falls apart at audit time.

How Do You Review Your Hiring Steps and Job Standards?

Next you look at how you actually hire. The rule wants your personnel processes to give known protected veterans careful, thorough, and systematic consideration. In plain terms, walk each step from job posting to offer. Check that a qualified veteran gets a fair look at every stage.

Write down that you did this review. Note the date. Note what you checked. Note anything you fixed. That written note is what an OFCCP reviewer wants to see.

Then review your job standards. A physical or mental standard that screens out disabled veterans must be job-related and a business necessity. The rule asks for a schedule to review these standards on a set cycle. A lifting rule or a vision rule may screen out a capable disabled veteran for no real reason. Check each one.

Two more duties sit close by. You provide reasonable accommodation to a qualified disabled veteran unless it would cause undue hardship. And you put procedures in place so veterans are not harassed for their status. Both belong in the veteran section.

What Counts as Veteran Outreach and Positive Recruitment?

This is the part reviewers dig into. The rule wants appropriate outreach and positive recruitment that is reasonably designed to reach protected veterans. It is not enough to post a job and wait. You have to go find the talent.

Then you have to prove it. Each year you assess whether your outreach actually worked. If a source sends few veterans, you can drop it and try another. The records of what you did and what you changed are the heart of a good-faith effort. We cover this in depth in building OFCCP good-faith-effort outreach records.

What sources count? State workforce agencies. Veteran service organizations. Base transition offices. Veteran job fairs. And veteran talent platforms. Naming a real, active source in your plan is far stronger than a vague line about veteran hiring.

This is where BMR fits your records. BMR adds over 1,000 new profiles a month. 77,901 resumes have been built on BMR. You can name it as an outreach source in the plan and review it each year.

One more outreach source is worth a line: SkillBridge. Hosting a SkillBridge participant is a documented way to reach transitioning service members. Your business must have been registered with a U.S. state for at least three years to host. See how it maps to your plan in SkillBridge as documented veteran outreach.

What Is the Hiring Benchmark and Where Does It Go?

The rule wants you to set a hiring benchmark each year. The benchmark is a target you measure your veteran hiring against. It comes from 41 CFR 60-300.45.

You have two ways to set it. The simple way is to use the national benchmark that OFCCP posts. The other way is to build your own number from labor data and your own hiring facts.

OFCCP set the national benchmark at 5.1 percent, effective July 30, 2025. Check the OFCCP hiring benchmark page for any newer figure. OFCCP is meant to update it each year, so look again before each plan cycle.

The benchmark sits next to your data. Each year you count your veteran applicants and hires. You compare the veteran share of your hires to the benchmark. A shortfall carries no automatic penalty. Use it as a cue to widen your outreach and write down what you will change.

To go deeper, read why the VEVRAA benchmark changes and how to document the benchmark every year. Both keep this section audit-ready.

How Do You Audit the Plan and Train Your Team?

A plan on a shelf does nothing. The rule wants an audit and reporting system that measures how well the plan works. Build one system that tracks your goals, flags weak spots, and records what you did to fix them.

Keep it simple. Review your numbers on a set schedule. Note where veterans drop out of the hiring flow. Write down the action you took. This is the paper trail that shows good faith.

Training is the other duty here. Anyone who touches recruiting, screening, selection, promotion, or discipline needs training on the plan. They should know the veteran commitments and how to carry them out. A short, dated training record covers this part.

Part of your data work also feeds the yearly VETS-4212 report and your job-listing duty. Covered contractors list job openings with the state workforce agency, with a few exceptions. See what contractors must post under the mandatory job listing rule so the same data does double duty.

How Long Do You Keep the Records?

Records make or break an audit. 41 CFR 60-300.80 sets the general rule. Keep personnel and employment records for two years. The clock starts at the record date or the personnel action, whichever is later.

A smaller contractor gets a shorter period. That means fewer than 150 employees or no contract of $200,000 or more. Those contractors keep general records for one year. Records tied to an open complaint or review stay until it is resolved.

Some records follow a longer rule. Outreach records, the yearly data collection analysis, and benchmark records stay for three years. That rule covers every contractor, small or large. The data lists veteran applicants, total applicants, job openings, jobs filled, veteran hires, and total hires.

Self-identification records ride along with all of this. You invite applicants to tell you if they are protected veterans, before and after an offer. Keep their answers confidential and share them with OFCCP on request. See how to invite the protected veteran self-identification form the right way.

What Trips Up the Veteran Section at Audit?

Weak veteran sections tend to share one flaw. They state good intent but show no proof. A reviewer grades your effort by the records behind it.

Look at the difference below. Both firms say they recruit veterans. Only one can back it up.

One part employers often forget is the flow-down. If you use subcontractors, you pass certain veteran clauses on to them in writing. Skip it and the gap shows up in your review. Read which VEVRAA clauses you flow down to subcontractors so your section is complete top to bottom.

How to Build the Veteran Section Without Guessing

The veteran section works like a checklist. Write the policy. Review your hiring steps and job standards. Name real outreach sources and log the results. Set the benchmark and compare your numbers. Audit, train, and keep the records for the right period.

Outreach is where reviewers dig in hardest. You need live sources that send veteran candidates. You also need dated proof that you used them. That proof feeds your yearly assessment and your three-year file.

BMR can be one of those named sources. Describe a role and see how many veterans who have consented to employer search match it. Filter by clearance, branch, state, or work location. A plan opens profiles and messaging, and interested candidates reply to you directly. Log BMR as a dated outreach source in your plan.