VEVRAA Compliance, Without the Jargon
If your company holds federal contracts, VEVRAA obliges you to do more than avoid discriminating against veterans — it obliges you to actively recruit them, and to write down what you did. Here is the whole obligation in plain English, sourced from OFCCP.
Does it apply to you?
VEVRAA — the Vietnam Era Veterans’ Readjustment Assistance Act, 38 U.S.C. 4212 — reaches any contractor or subcontractor holding a covered federal contract. The current reporting threshold is $150,000.
The threshold is the single most-misquoted number in this area. OFCCP’s regulations at 41 CFR 60-300 still read $100,000. But Congress requires the FAR Council to review acquisition thresholds for inflation every five years (41 U.S.C. 1908), and OFCCP has adopted the adjusted figure. Quote the regulation and you will be wrong by $50,000.
Who counts as a protected veteran
Four categories, per OFCCP. Someone needs to fall into only one:
- Disabled veterans
- Recently separated veterans
- Active-duty wartime or campaign badge veterans — “period of war” here follows Title 38, which includes the Persian Gulf War period running from 2 August 1990 to the present. In practice that sweeps in most people who have served in the last three decades.
- Armed Forces service medal veterans
The seven things you actually have to do
- Do not discriminate. The baseline: no adverse action on the basis of protected veteran status, and no retaliation for protected activity.
- Take affirmative action to recruit, hire, promote and retain. This is the active half of the obligation, and the half people forget.
- List your openings with the employment service delivery system (ESDS) in a format that ESDS accepts — indicating on your initial listing that you are a federal contractor seeking priority referrals of protected veterans, and supplying contact details for the official responsible for hiring at each hiring location in the state.
- Invite applicants to self-identify, both pre-offer and post-offer.
- Set a hiring benchmark every year if you are required to maintain a written affirmative action program. How the benchmark works →
- Collect and document the numbers annually — see below.
- File your VETS-4212 report between 1 August and 30 September. The filing guide →
The data you must document every year
41 CFR 60-300.44(k) requires contractors to document and update, annually:
- the number of protected veteran applicants
- the total number of job openings and the number of jobs filled
- the total number of applicants for all jobs
- the total number of protected veteran applicants hired
- the total number of applicants hired
Keep it for three years. The retention period is not administrative housekeeping — it exists so that you, and OFCCP, can see whether outreach is working over time rather than in a single snapshot.
Outreach has to be assessed, not just performed
This is the requirement most contractors underestimate. You must undertake outreach and positive recruitment reasonably designed to recruit protected veterans — and then annually assess whether it worked, and write that assessment down. The evaluation has to state the criteria you used and your conclusion on each effort.
Then comes the part with teeth. If you conclude that the totality of your efforts was not effective at identifying and recruiting qualified protected veterans, the regulations require you to implement alternative methods. Documenting that something did not work, and then doing the same thing next year, is not compliance.
An internal audit and reporting system
VEVRAA regulations also require contractors to design and implement an internal audit and reporting system for the affirmative action program — a mechanism for measuring whether the programme is actually being carried out, not merely written down.
This is not legal advice. LockLeed International is a veteran-owned staffing agency — not a law firm, not a compliance consultancy, and not affiliated with the U.S. Department of Labor or OFCCP. Everything here is summarised from public DOL and OFCCP guidance and was checked against those sources on 1 August 2026. Regulations change: the Department published a Notice of Proposed Rulemaking on 1 July 2025 proposing modifications to the VEVRAA regulations, so confirm anything that matters with your own counsel or with OFCCP before acting on it.
Common Questions
Who has to comply with VEVRAA?
Federal contractors and subcontractors holding a covered contract at or above the current reporting threshold of $150,000. Note that OFCCP's regulations at 41 CFR 60-300 still state $100,000; the FAR Council raised acquisition thresholds for inflation and OFCCP applies the adjusted figure.
Who is a protected veteran under VEVRAA?
Four categories: disabled veterans, recently separated veterans, active-duty wartime or campaign badge veterans, and Armed Forces service medal veterans. The wartime period under Title 38 includes the Persian Gulf War period from 2 August 1990 to the present.
Is missing the VEVRAA hiring benchmark a violation?
No. The benchmark is a yardstick for measuring the effectiveness of outreach and recruitment, not a quota, and falling below it is not itself a violation. However, if a contractor concludes its outreach efforts were not effective, the regulations require it to implement alternative methods.
How long must VEVRAA records be kept?
Three years for the annual data collection analysis, the benchmark records, and the documented assessments of outreach and recruitment effectiveness.
The Rest of the Picture
VETS-4212 Filing Guide
Who must file VETS-4212, the 1 August to 30 September window, the $150,000 threshold, batch filing, and where filings go wrong.
VEVRAA Hiring Benchmark
What the VEVRAA hiring benchmark is, the current 5.1% national figure, the five-factor alternative, and why it applies to each establishment separately.
Below the Benchmark
Coming in under the 5.1% VEVRAA benchmark is not a violation — but it does trigger a documented obligation. What OFCCP expects, and how to close the gap.
We Don't Do Paperwork. We Do Candidates.
Filing the form is your job, and it is not the hard part. Hiring enough qualified veterans to move the number is what most contractors struggle with — and that is the only part we do. Veteran-owned, nationwide, fee only on a hire.