The DOL final rule, effective September 21, 2026, rescinds several Section 503 compliance requirements, including mandatory disability self-identification, the 7 percent utilization goal, and related data collection obligations. This implementation substantially revises the regulations in Section 503 of the Rehabilitation Act of 1973, as amended (“Section 503”).
Core Section 503 obligations remain in place, including nondiscrimination, affirmative action planning, outreach, reasonable accommodation, personnel process review, and record preservation.
The DOL says the self-identification requirement conflicts with the ADA, and it says the utilization goal is no longer workable and could encourage prohibited quotas.
The rule does not affect separate state disability affirmative action requirements, which may still require disability data collection in some jurisdictions.
Contractors should update compliance policies and forms before the deadline, stop using Form CC-305 for Section 503 purposes, remove utilization analyses from AAP materials, and retain existing data under record-retention rules.
Read more about the DOL Final rule on the JDSupra website
Mobile accessibility tells half the story
September 8, 2026
I audited five public design systems. The one built for mobile, Material 3, hands designers accessibility as first-class properties. The web still treats the same
Mark SMiller is a digital accessibility consultant who helps organizations build accessible, inclusive digital experiences. He speaks regularly at industry conferences,, CSUN, CVENt and apperes on many webinars and podace. , He trains teams on practical, sustainable accessibility workflows.
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