In a bulletin issued on November 25, 2025, the OFCCP announced that, as of October 1, 2025, the federal contractor and subcontractor jurisdictional thresholds for individuals with disabilities pursuant to Section 503 of the Rehabilitation Act (“Section 503”), and for protected veterans under the Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) have increased.

The basic coverage threshold for Section 503 has increased from $15,000 to $20,000, with Section 503 “Affirmative Action Program” (“AAP”) requirements applying to covered contractors and subcontractors with at least 50 employees and a single contract of $50,000 or more.  The VEVRAA threshold has increased from $150,000 to $200,000, with VEVRAA AAP requirements applying to covered contractors and subcontractors with at least 50 employees and a single contract of $200,000 or more.  

In connection with these changes, OFCCP has issued a new “Jurisdictional Thresholds” infographic and updated its webpage on “Jurisdiction Thresholds and Inflationary Adjustments under Section 503 and VEVRAA” in order to “help[] employers, employees, and other interested parties easily determine when OFCCP’s Section 503 and VEVRAA regulations apply to contractors doing business with the federal government.” 

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Photo of Guy Brenner Guy Brenner

Guy Brenner is a partner in the Labor & Employment Law Department and leads the Firm’s Washington, D.C. Labor & Employment practice. He is head of the Government Contractor Compliance Group, co-head of the Counseling, Training & Pay Equity Group and a member…

Guy Brenner is a partner in the Labor & Employment Law Department and leads the Firm’s Washington, D.C. Labor & Employment practice. He is head of the Government Contractor Compliance Group, co-head of the Counseling, Training & Pay Equity Group and a member of the Restrictive Covenants, Trade Secrets & Unfair Competition Group. He has extensive experience representing employers in both single-plaintiff and class action matters, as well as in arbitration proceedings. He also regularly assists federal government contractors with the many special employment-related compliance challenges they face.

Guy represents employers in all aspects of employment and labor litigation and counseling, with an emphasis on non-compete and trade secrets issues, medical and disability leave matters, employee/independent contractor classification issues, and the investigation and litigation of whistleblower claims. He assists employers in negotiating and drafting executive agreements and employee mobility agreements, including non-competition, non-solicit and non-disclosure agreements, and also conducts and supervises internal investigations. He also regularly advises clients on pay equity matters, including privileged pay equity analyses.

Guy advises federal government contractors and subcontractors all aspects of Office of Federal Contract Compliance Programs (OFCCP) regulations and requirements, including preparing affirmative action plans, responding to desk audits, and managing on-site audits.

Guy is a former clerk to Judge Colleen Kollar-Kotelly of the US District Court of the District of Columbia.

Photo of Olympia Karageorgiou Olympia Karageorgiou

Olympia Karageorgiou is an associate in the Labor Department and a member of the Employment Litigation & Arbitration Group.

During her time at Proskauer, Olympia has focused on a wide range of employment matters, including employment discrimination litigation, due diligence, and policies, handbooks…

Olympia Karageorgiou is an associate in the Labor Department and a member of the Employment Litigation & Arbitration Group.

During her time at Proskauer, Olympia has focused on a wide range of employment matters, including employment discrimination litigation, due diligence, and policies, handbooks and training, among others. Olympia has gained experience across a wide variety of industries including financial services, education, sports, and media and entertainment.

Olympia earned her J.D. from Yale Law School, where she was co-director of the Clinical Student Board and a member of the Reentry Clinic. While at Yale, she was also Academic Development co-chair of the Yale Black Law Students Association and served as a director of the Rebellious Lawyering Conference.

Prior to law school, Olympia was an AmeriCorps member in Dallas, Texas, focusing on issues related to education and social equity.