As its landmark initiative, the Obama Administration’s Office of Federal Contract Compliance Programs (“OFCCP”) issued expansive new regulations requiring government contractors to undertake greater efforts to employ veterans and individuals with disabilities. The regulations implement the Vietnam Era Veterans’ Readjustment and Assistance Act, as amended, (“VEVRAA”) and Section 503 of the Rehabilitation Act of 1973 (“Section 503”), which prohibit discrimination against and require affirmative action in employment for certain classes of veterans and for individuals with disabilities.

The most controversial of the requirements – hiring benchmarks for veterans and utilization goals for individuals with disabilities – have an effective date that depends on the start date for each contractor’s affirmative action plan (“AAP”) year. Some provisions, however, go into effect on March 24, 2014, and the OFCCP encourages contractors to begin early implementation of other regulatory provisions.