VEVRAA Compliance for Federal Contractors Hiring Veterans
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You won a federal contract. Good news. Now you have a new set of rules to follow. One of them is VEVRAA. If you have never dealt with it, the acronym alone can make your head spin.
VEVRAA stands for the Vietnam Era Veterans' Readjustment Assistance Act. It is the law that tells federal contractors to recruit, hire, and support protected veterans. It is not new. But the rules around it shifted in 2025. Some thresholds went up. One big affirmative action order got rescinded. A lot of HR teams are confused about what still applies.
This guide walks through the core VEVRAA compliance obligations in plain terms. Who is covered. What you have to do. What you have to file. What records to keep. And what an audit looks like. We sell veteran talent for a living, so we live next to these rules every day. Let me lay it out the way I wish someone had laid it out for me.
This is a guide, not legal advice
VEVRAA rules and enforcement are shifting in 2026. Thresholds and benchmarks change. Always confirm the current figures on the OFCCP and DOL VETS sites, and loop in your compliance counsel before you act.
What is VEVRAA and who enforces it?
VEVRAA is a federal law. You can find it at 38 U.S.C. section 4212. The rules that put it into practice live at 41 CFR Part 60-300.
The law has one job. It tells companies that take federal contracts to give protected veterans a fair shot. That means active recruiting. Fair hiring. No discrimination. And steps to support veterans once they are on the team.
The agency that enforces it is the Office of Federal Contract Compliance Programs. People call it OFCCP. It sits inside the U.S. Department of Labor. OFCCP runs the audits. It checks your records. It makes sure you are doing what the law asks.
One more group matters here. The Veterans' Employment and Training Service, or VETS. It also sits inside DOL. VETS handles one specific report you have to file each year. We will get to that.
Who counts as a protected veteran?
VEVRAA does not cover every veteran. It covers four protected groups:
- Disabled veterans: service members with a service-connected disability rating, or who were discharged or released for a service-connected disability.
- Recently separated veterans: those within three years of discharge or release from active duty.
- Active duty wartime or campaign badge veterans: those who served during a war or in a campaign for which a badge was authorized.
- Armed Forces service medal veterans: those who got an Armed Forces service medal for a covered operation.
A veteran only needs to fit one group to be protected. Many fit more than one.
Does VEVRAA apply to your company?
This is the first question to settle. VEVRAA does not apply to every business. It applies based on the size of your federal contract.
The dollar threshold went up in 2025. As of October 1, 2025, basic VEVRAA coverage kicks in when you hold a single federal contract of $200,000 or more. That figure used to be $150,000. So if you read an older guide that says $150,000, it is out of date.
Basic coverage means the core duties apply. You must not discriminate against protected veterans. You must take active steps to recruit and hire them. You must include a specific equal opportunity clause in covered subcontracts.
When do you need a written affirmative action program?
There is a second, higher bar. A written affirmative action program, or AAP, is a formal document. Not every contractor has to build one.
You need a written VEVRAA AAP when you meet both of these:
- Employee count: 50 or more employees.
- Contract size: a single federal contract of $200,000 or more.
Miss either one and you do not owe a written AAP. A 30-person shop with a $500,000 contract still has the basic duties. But it does not build the formal written program. A 200-person firm with a $250,000 contract does build one.
- •No discrimination against protected veterans
- •Active recruiting and outreach
- •Equal opportunity clause in covered subcontracts
- •Annual VETS-4212 report (at $150,000+)
- •Everything in column A, plus:
- •A formal written affirmative action program
- •A set hiring benchmark and data tracking
- •Documented self-analysis each year
What does the VEVRAA affirmative action program require?
If you hit the AAP bar, you build a written program. It is not a one-page policy. It is a working document you update each year. Here is what goes in it.
First, a policy statement. You put it in writing that you recruit, hire, and advance protected veterans. Leadership signs it. It is not buried in a handbook nobody reads.
Second, a review of your personnel processes. You look at how you recruit and hire. You check for barriers that keep veterans out. You fix the ones you find.
Third, outreach and recruiting. You build real ties to sources of veteran talent. State workforce agencies. Veteran service organizations. Transition programs on military bases. You track which sources work and which do not.
Fourth, the hiring benchmark. This is the number people focus on most, so it gets its own section below.
How does the VEVRAA hiring benchmark work?
The hiring benchmark is a yearly target. OFCCP sets a national benchmark each year. It is meant to reflect the share of veterans in the civilian workforce. It has been around 5 percent in recent years. As of this writing the national benchmark is 5.1 percent, effective July 30, 2025.
That number changes most years. Do not hardcode it into your program. Check the current figure on the OFCCP site before each cycle.
You can set your benchmark one of two ways. You can adopt OFCCP's national number. Or you can build your own using a five-factor method tied to your local labor data. The national number is simpler. The five-factor method takes more work but can fit your market better.
One thing matters a lot here. The benchmark is a goal, not a quota. Missing it is not a violation by itself. You do not get fined for falling short of 5.1 percent. What OFCCP wants to see is that you set the benchmark, you track your results against it, and you act on the gap. A contractor who never set a benchmark is in worse shape than one who set it and missed.
The benchmark deep-dive is its own topic. We break down both methods, the data you compare against, and how to document the analysis in our companion piece on the OFCCP veteran hiring benchmark. Read that one if you own the tracking.
"The benchmark is a goal, not a quota. OFCCP does not fine you for missing the number. It checks whether you set it, tracked it, and acted on the gap."
What is the VETS-4212 report and when is it due?
The VETS-4212 is a yearly report. It is separate from your AAP. And it goes to a different office.
You file the VETS-4212 with DOL VETS, not OFCCP. You can find the program at DOL VETS. The report counts your protected veterans. It breaks them down by job category and by hiring location. It also counts your new hires and how many of them were protected veterans.
The threshold for this report is a single contract of $150,000 or more. Note that this is a lower bar than the $200,000 VEVRAA coverage figure. So a contract between $150,000 and $200,000 can owe the VETS-4212 report even when it falls below the main VEVRAA threshold. Check both numbers against your contract.
The filing season runs from August 1 to September 30 each year. You file online through the VETS-4212 application. Miss the window and you risk a finding. Put it on the calendar now if it applies to you.
VETS-4212 at a glance
Who files
Contractors with a single contract of $150,000 or more
Where it goes
DOL VETS, not OFCCP
When it is due
Filing season August 1 to September 30 each year
What it reports
Protected veterans and new hires by job category and location
What is the equal opportunity clause?
VEVRAA asks you to flow the rules down. You do this through an equal opportunity clause. It goes into your covered contracts and subcontracts.
The clause does two things. It states that you do not discriminate against protected veterans. And it binds your subcontractors to the same duty when their work meets the threshold.
This part trips people up. You can be fully compliant in your own shop and still have a gap if your subcontracts are missing the clause. Check your contract templates. Make sure the language is in there for covered work.
What records do you have to keep?
Recordkeeping is where a lot of audits get won or lost. You can do the work and still fail if you cannot prove it.
Keep records of your outreach. Which veteran sources you used. Which job openings you posted. How your recruiting played out. Keep your applicant and hire data. Keep the self-ID forms where applicants tell you if they are protected veterans.
The standard retention period is two years for most contractors. Smaller contractors keep records for one year. That is contractors with fewer than 150 employees or a contract under $150,000. A few specific AAP activity documents carry a longer three-year requirement, like outreach records and benchmark tracking. When in doubt, hold them longer.
1Self-identification forms
2Outreach records
3Applicant and hire data
4Benchmark comparison
What happens in an OFCCP audit?
OFCCP can pick your company for a compliance review. It often starts with a scheduling letter. The letter asks for your AAP and your supporting data.
The agency reviews what you send. It checks your outreach. It checks your benchmark and how you tracked it. It checks your applicant and hire numbers for signs of a problem.
Most reviews end without a fight. If OFCCP finds a gap, it usually works with you to fix it. A finding is most often about process. You did not set a benchmark. You did not track your data. You did not act on a shortfall. The number itself is rarely the issue.
The best defense is boring. Set your benchmark. Run your outreach. Keep your records. Do your yearly self-analysis. If your file shows a real, good-faith effort, an audit is a paperwork exercise, not a crisis.
Did the 2025 executive order changes end VEVRAA?
This is the question I get most from contractor HR teams right now. The short answer is no. But it needs care, because the ground is moving.
In early 2025, an executive order rescinded Executive Order 11246. That older order covered affirmative action on race and sex for federal contractors. Its rescission got a lot of press. Some teams read the headlines and assumed all contractor affirmative action ended.
It did not. VEVRAA and Section 503 are different. VEVRAA covers protected veterans. Section 503 covers people with disabilities. Both are statutory. That means Congress wrote them into law. An executive order cannot erase a statute. So the veteran duties under VEVRAA stayed in force.
That said, the enforcement picture is shifting in 2026. OFCCP has proposed rule changes. There has been talk of winding down some contractor mandates. There have even been proposals about the agency's future. None of that repeals VEVRAA. But it does mean the day-to-day enforcement posture can change.
So do not assume VEVRAA is dead. And do not assume nothing has changed. Confirm the current OFCCP and DOL VETS guidance before each cycle, and check with your compliance counsel. That is the honest answer in a year where the rules are in motion.
Key Takeaway
EO 11246 was rescinded in 2025. VEVRAA was not. The veteran affirmative action duty is statutory and still applies in 2026. Confirm the current enforcement posture before you act.
How do you turn compliance into a real hiring win?
Here is the part most compliance guides skip. VEVRAA is not just a box to check. Done right, it builds a real veteran pipeline. The same outreach that satisfies the rule also fills your roles with strong people.
The contractors who do this well stop treating veteran hiring as paperwork. They build steady sources of veteran talent. They write job posts that veterans can read and apply to. They train recruiters to read a military resume without getting lost in the jargon.
If you want the playbook for the recruiting side, start with our veteran recruiting strategy playbook. If you need to sell the program inside your own walls, the internal business case for veteran hiring lays out the numbers. To reach service members early, see how to hire transitioning service members before separation. And when veteran resumes start landing, the recruiter's checklist for screening veteran applicants keeps your team consistent.
This is where a sourcing partner helps. Best Military Resume sees over 1,000 new veteran profiles every month, with more than 60,000 resumes built on the platform. That is a steady, growing pool of veteran talent ready to apply. For a contractor working a VEVRAA benchmark, a fresh source like that does double duty. It feeds your roles and it feeds your outreach records at the same time.
If you want to plug into that pool, partner with us. We connect employers with veteran talent and help you build a pipeline that holds up to an audit and fills real seats.
The bottom line
VEVRAA is not as scary as the acronym makes it sound. Figure out if you are covered. Build the AAP if you cross the bar. Set your benchmark. File the VETS-4212 on time. Keep clean records. Do your yearly review.
The contractors who get tripped up are not the ones who miss the benchmark. They are the ones who never set it up and cannot show their work. Get the process right and the rest takes care of itself. And while you are at it, build a veteran pipeline that does more than satisfy a rule. It can become one of the best sources of talent you have.
Frequently Asked Questions
QWhat is VEVRAA in simple terms?
QWhat is the VEVRAA contract threshold?
QIs missing the VEVRAA hiring benchmark a violation?
QWho has to file the VETS-4212 report and when?
QDid the 2025 executive order rescinding EO 11246 end VEVRAA?
QHow long must federal contractors keep VEVRAA records?
QWhat does an OFCCP audit check for VEVRAA?
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.
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