Federal contractors and subcontractors should remain mindful that their obligations relating to protected veterans remain in full force despite developments affecting other federal contractor compliance requirements. In particular, covered employers should be preparing now for the upcoming VETS-4212 filing deadline and ensuring that their hiring and workforce data regarding protected veterans is accurate and complete. This update highlights the current VETS-4212 reporting requirements, key filing deadlines, and other continuing obligations applicable to federal contractors and subcontractors with respect to protected veterans.
VETS 4212 Annual Report:
Employers that hold a federal contract or subcontract valued at $200,000 or more are required to file a VETS-4212 Report, regardless of the size of their workforce. The U.S. Department of Labor’s VETS-4212 Reporting Application is now accepting submissions for the annual report for the 12-month “reporting period.” The “reporting period” is the 12-months preceding the selected payroll period ending date; to determine the “reporting period” you should select a date in the applicable year between July 1 and August 31 that represents the end of a payroll period. In addition, the Department of Labor also provides that you could use the 12-month period ending December 31 as the “reporting period” for the 2025 filing cycle. The annual filing window opened August 1, 2026, and will remain open through September 30, 2026.
The VETS-4212 Report requires employers to provide employee and hiring data by EEO-1 job category for each hiring location and the company headquarters, including total employees (as of selected payroll period end date), total protected veterans (as of selected payroll period end date), the total number of new hires (as of 12-month “reporting period” ending on the selected payroll period date), and the total number of protected veteran new hires (as of 12-month “reporting period” ending on the selected payroll period date).
If you are a covered federal contractor or subcontractor, you should begin reviewing and reporting your data to ensure accurate and timely filing before the September 30 deadline.
Updates on Additional Obligations:
At this time, there is no substantive update regarding the 2025 EEO-1 Report. Although the EEOC has proposed rescinding the EEO-1 reporting requirements, that proposal has not been finalized, and employers should continue to anticipate that a 2025 EEO-1 filing will be required. The EEOC has not yet announced the filing window or deadline, but we expect additional guidance in September.
Employers should also note that the significant upcoming changes to OFCCP obligations relating to individuals with disabilities do not affect federal contractor obligations regarding protected veterans. While the future of certain disability-related affirmative action and self-identification requirements remains uncertain, the VEVRAA requirements applicable to protected veterans, including the annual VETS-4212 Report and veteran-related affirmative action obligations, remain in effect. Accordingly, covered federal contractors and subcontractors should continue to comply with all existing protected veteran requirements and prepare for the upcoming VETS-4212 filing deadline.
If you have questions about your obligations as a federal contractor or subcontractor, please contact Jack Rowe or Natalie Kay, or your regular Lathrop GPM attorney.