Nearly every federal contract worth $150,000 or more carries a clause numbered 52.222-35. It runs a few sentences, and most hiring managers never read it. That clause binds the contractor to one regulation, 41 CFR 60-300.5(a), and the regulation issues an order with real teeth: list almost every job opening you have with the public workforce system, and list it immediately.

That order survived the largest shift in contractor compliance in a generation. On January 21, 2025, Executive Order 14173 revoked Executive Order 11246, the 1965 rule behind the race and sex affirmative-action programs the Office of Federal Contract Compliance Programs had enforced for decades. The job-posting duty never came from that executive order. It comes from an act of Congress, the Vietnam Era Veterans’ Readjustment Assistance Act, and Congress did not repeal it. A contractor who reads only the 2025 headline can walk straight past a duty that is fully live in 2026.

Did the 2025 affirmative-action rollback end OFCCP’s job posting requirements?

No. The posting duty rests on VEVRAA, a statute at 38 U.S.C. 4212, not on the revoked Executive Order 11246. EO 14173 ordered OFCCP to stop enforcing race and sex affirmative action as of January 21, 2025, with a 90-day wind-down to April 21, 2025. VEVRAA and Section 503 both survived.

Three contractor obligations used to travel together, and the distinction between them decides everything now. The first was the Executive Order 11246 program covering race, color, religion, sex, and national origin. The second is Section 503, protecting individuals with disabilities. The third is VEVRAA, protecting certain veterans. Only the first was built on an executive order, and EO 14173 revoked only that one, directing OFCCP to immediately cease holding contractors responsible for affirmative action as understood under EO 11246 and to stop encouraging workforce balancing. The other two are acts of Congress. VEVRAA sits on 38 U.S.C. 4212; Section 503 sits on 29 U.S.C. 793. Revoking an executive order does not repeal a statute, so the veteran job-listing duty and the disability affirmative-action duty both carried forward intact. If you are not certain your company is even a covered contractor, our explainer on government contract jobs versus federal jobs draws that line first, and the broader OFCCP compliance picture for federal contractors puts the posting rule in context.

Which job openings must a federal contractor list?

Nearly all of them. “All employment openings” under 41 CFR 60-300.5 covers full-time, part-time, and temporary roles lasting more than three days. Only three categories fall out: executive and senior management, positions filled entirely from within, and positions that last three days or less.

The rule reads “all employment openings” and means it. A req is covered whether it is full-time, part-time, or a temporary assignment longer than three days. The exits are narrow and enumerated. The executive and senior-management carve-out is not a label you assign; it is a test. An employee qualifies only when paid on a salary basis of at least $455 a week, or $380 a week in American Samoa, with a primary duty of managing the enterprise, direction of two or more employees, and authority to hire or fire, or when the person holds a bona fide 20-percent equity interest and actively manages the business. A mid-level program manager on a defense contract almost never meets that standard, so the requisition is listable. The filled-from-within exception holds only until you consider a single outside applicant, at which point the duty snaps back. A security clearance is not on the list of exceptions at all, so a Secret or TS/SCI billet opened to outside candidates is a covered opening. You advertise that the vacancy exists and how to apply, not the classified program behind it. The mechanics of the listing itself, and the penalty ladder for skipping it, are laid out in our companion piece on the VEVRAA mandatory job listing.

Where, exactly, does the opening have to be posted?

With the appropriate employment service delivery system, the public labor exchange in the state where the opening occurs. Listing with the state workforce agency job bank satisfies it. A private job board counts only if it passes the vacancy to that system in a form that allows priority referral of protected veterans.

You are not filing anything with OFCCP. The clause hands the opening to the public labor exchange your state already runs, called the employment service delivery system, and 41 CFR 60-300.5(a) makes the state workforce agency job bank the easy path. The point of the listing is priority referral. Under 41 CFR 60-300.84, the state system is required to refer qualified protected veterans to your listed openings and to give them priority in those referrals. A privately run job board or exchange satisfies your duty only where it provides the opening to the state system in a manner and format that lets the system make that priority referral. Timing is written in too. The listing must run at least concurrently with any other recruiting source, so posting to your careers page and a niche board on Monday means the state listing goes up in the same window, not next week. Listing carries the normal duties of a bona fide job order, including accepting referrals, but it does not require you to hire any particular applicant. One setup step is easy to miss: the contractor must formally tell the employment service in each state where it has establishments that it is a federal contractor seeking priority veteran referrals, and provide each hiring location and a responsible hiring contact. In many cleared shops that whole compliance line lives with the Facility Security Officer, whose broader remit our guide to FSO requirements for a cleared contractor walks through.

What dollar thresholds turn each duty on?

OFCCP’s jurisdictional floor is a contract of $100,000 or more. The FAR inserts the veterans clause at $150,000. Section 503 for disability reaches contracts over $10,000 but carries no listing duty. The annual VETS-4212 report follows the $150,000 FAR trigger.

The thresholds get merged into one number all the time, and the difference matters when a contract sits between them. VEVRAA coverage attaches at $100,000 or more under the statute and 41 CFR 60-300.1. The acquisition regulation is more forgiving about paperwork: FAR 22.1303 sets the veterans clause’s reach at contracts expected to be worth $150,000 or more, so the contracting officer inserts clause 52.222-35 only at that value, and the same section ties the VETS-4212 reporting duty to the $150,000 line. Section 503, resting on 41 CFR 60-741, sweeps in far smaller contracts of more than $10,000 and demands affirmative action for individuals with disabilities. What it never demands is a state job-bank listing. That absence is the point worth remembering: there is no disability equivalent to the veteran listing mandate, so do not send disability openings to a state job bank thinking a rule requires it.

The reader’s actual contract language is FAR 52.222-35, which binds the contractor to the equal-opportunity clause at 41 CFR 60-300.5(a). The listing duty is written into the contract, not layered on top of it.

Beyond the listing, what else must a contractor post or file?

Four more duties ride with the listing: a one-time federal-contractor notice to each state’s employment service, the veterans’-rights posting in physical and electronic form, an annual VETS-4212 report, and, for larger contractors, a written affirmative action program prepared within 120 days.

The listing is the front door, and a short checklist of obligations sits behind it. The contractor must post the prescribed veterans’-rights notice in conspicuous places for employees and applicants, and an electronic posting is required when the company runs an electronic application process, which reaches remote applicants who never see a breakroom wall. A covered contractor files the VETS-4212 report at least annually, tallying employees and protected veterans by category and hiring location, and the FAR ties that filing to the $150,000 threshold. The larger obligation is the affirmative action program under 41 CFR 60-300.40: a contractor with 50 or more employees and a contract of $100,000 or more prepares and maintains a written VEVRAA program at each establishment within 120 days of the contract’s start. That program is also where the hiring benchmark lives. Under 41 CFR 60-300.45, the contractor sets an annual veteran hiring benchmark, adopting either the national percentage of veterans in the civilian labor force that OFCCP publishes each year or an individualized figure built from a multi-factor state method. The regulation is blunt that this is a yardstick for outreach and that quotas are forbidden, so confirm the current national figure on OFCCP’s benchmark page for your program year rather than guessing at it. Cleared employers already carry heavy fixed costs to bring a candidate on, a reality our breakdown of the cost of sponsoring a clearance spells out, which makes the free veteran referral channel worth keeping open.

None of this needs new legislation to bite in 2026. The regulations are current, the contract clause is already in your file, and the hiring environment gives you every reason to keep the referral channel live even when headcount is tight, as our read on the DoD hiring freeze and cleared jobs lays out. Before your next VETS-4212 report comes due in 2026, take one quarter of your open requisitions and test each against the three exceptions in 60-300.5. Whatever fails the test, and for a cleared contractor that is most of the board, belonged in the state job bank the day the requisition opened.

Frequently Asked Questions

Do OFCCP’s job posting requirements still apply after the 2025 executive order?

Yes. Executive Order 14173 revoked Executive Order 11246 on January 21, 2025, but the job-listing duty comes from VEVRAA, a statute at 38 U.S.C. 4212, with its own regulation at 41 CFR part 60-300 that remains current in 2026. Section 503 for disability also survived. Only the race and sex affirmative-action program built on the executive order was revoked.

What dollar amount triggers the veteran job-listing requirement?

OFCCP’s jurisdictional floor is a contract or subcontract of $100,000 or more under 38 U.S.C. 4212 and 41 CFR 60-300.1. The acquisition regulation, however, inserts the Equal Opportunity for Veterans clause (52.222-35) and its listing duty only at $150,000 or more, and sets the VETS-4212 report at that same figure. Read the clause your contract actually cites and apply both numbers to the right duty.

Does Section 503 require me to post disability openings to a state job bank?

No. Section 503, at 41 CFR part 60-741, covers contracts over $10,000 and requires affirmative action for individuals with disabilities, but it contains no state-job-bank listing clause. The mandatory listing with the employment service is a VEVRAA duty only. Do not route disability openings to a state job bank on the belief that a rule requires it.

Do cleared or classified positions have to be listed?

Yes. A security-clearance requirement is not one of the three exceptions in 41 CFR 60-300.5. A cleared requisition opened to outside candidates is a covered opening unless it independently qualifies as executive or senior management, is filled entirely from within, or lasts three days or less. You list the job vacancy in a form that lets the state system offer priority referral to protected veterans, not the classified details of the program.

Where do I actually post the opening to satisfy the rule?

With the appropriate employment service delivery system, the public labor exchange in the state where the opening occurs. Listing with the state workforce agency job bank or the local employment service satisfies the duty, and it must run at least concurrently with any other recruiting source. A private job board counts only if it passes the vacancy to the state system in a format that allows priority referral of protected veterans.