Job posting requirements for federal contractors after EO 11246

As of October 2026, a federal contractor's job ads no longer need the familiar race and sex "equal opportunity employer" tagline as a federal contract requirement, because Executive Order 11246 was revoked in January 2025 and its regulations are removed on October 26, 2026. Two sets of posting rules survive, because they come from statutes rather than an executive order. Contractors covered by the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) must state in every ad that qualified applicants will be considered without regard to protected veteran status, and must list nearly every opening with the state job bank. Contractors covered by Section 503 of the Rehabilitation Act must say the same about disability.

Below: what changed and when, the wording each rule requires, how the state job bank listing works, the general advertising rules that apply to every employer, and a checklist for posting a contractor role. For the applicant counting that follows the posting, see the Internet Applicant rule in 2026.

What changed in 2025 and 2026

One addition to know about: in May 2026 acquisition.gov published a new clause, 52.222-90, implementing Executive Order 14398, "Addressing DEI Discrimination by Federal Contractors," of March 26, 2026. The announcement does not mention job advertisements, and we have not verified the clause's terms, so read it in the contract before deciding what it means for recruiting materials.

The wording job ads must include

Both surviving rules attach to "all solicitations or advertisements for employees placed by or on behalf of the contractor." That covers job board posts, careers pages, social posts and ads placed by an agency for the client.

A single sentence can satisfy both, for example: "All qualified applicants will receive consideration for employment without regard to protected veteran status and will not be discriminated against on the basis of disability." Many employers will also keep a general equal opportunity statement because state law, a client policy or their own preference calls for one. Whether to keep the old EO 11246 wording is a decision for the client; it is no longer a federal contract requirement after October 26, 2026.

Shorthand such as "EOE/Vets/Disability" is common. The regulations describe what must be stated, not a required form of words, and we did not find current OFCCP guidance approving abbreviations, so the full sentence is the safer choice.

Listing openings with the state job bank

This is the VEVRAA requirement that most often gets missed, because it is not about wording. Under paragraphs 2 through 6 of the clause in 41 CFR 60-300.5(a):

• What: the contractor must immediately list all employment openings that exist when the contract is signed and that occur during its performance.
• Where: with the appropriate employment service delivery system where the opening occurs, which in practice is the state workforce agency job bank or the local employment service office. A privately run job service may be used if it passes the listing on in a format the state system accepts.
• When: at least concurrently with any other recruitment source or effort. Posting on a job board on Monday and the state job bank on Thursday does not meet this.
• What to tell the state system: that the employer is a federal contractor and wants priority referrals of protected veterans, the name and location of each hiring location in the state, and contact information for the official responsible for hiring.
• What is excluded: executive and senior management positions, positions that will be filled from within the contractor's organization, and positions lasting three days or less. Openings that occur and are filled outside the United States and its listed territories are also excluded.

The "filled from within" exclusion is narrow. It covers openings for which no one outside the organization will be considered. If an internal posting might turn into an external search, list it with the state job bank before going outside. For internal postings that really are internal-only, see the internal job posting template.

Rules on ads that apply to every employer

The contractor rules sit on top of general advertising law, which applies whether or not there is a federal contract:

• Title VII. 42 U.S.C. § 2000e-3(b) makes it unlawful for an employer or employment agency to publish an employment notice or advertisement indicating a preference, limitation or specification based on race, color, religion, sex or national origin, except where religion, sex or national origin is a bona fide occupational qualification.
• Age. 29 U.S.C. § 623(e) does the same for age, so phrases such as "recent graduate" or "young and energetic" invite trouble.
• Criminal history. For positions related to work under a covered contract, the Fair Chance Act bars requesting criminal history before a conditional offer, with limited exceptions; see ban-the-box laws.
• Pay ranges. The federal pay transparency provision was about not retaliating against pay discussions, and it is gone. State and city laws requiring a pay range in the ad are separate and still apply; see pay transparency laws by state.
• Work authorization. Contracts with the FAR E-Verify clause require E-Verify for new hires and some existing employees working on the contract. The verification happens after hire, not in the ad; see E-Verify requirements by state.

For agencies posting on a contractor's behalf

The obligations belong to the contractor, but the ad rules expressly reach ads placed on the contractor's behalf, so an agency's posting is the client's posting. Three habits avoid most problems:

1. Ask at intake whether the role is covered. "Is this position connected to a federal contract or subcontract, and above which thresholds?" Write the answer on the job order.
2. Use the client's statement word for word. Do not shorten it to fit a job board's character limit without asking.
3. Confirm the state job bank listing before you post. Because listing must be at least concurrent with other recruitment, your post going live first can put the client out of compliance.

A checklist for posting a contractor role

FEDERAL CONTRACTOR POSTING CHECK — [role] — [req #] — [date]
Contract link confirmed:           yes / no   Contract value band: [ ]
VEVRAA covered ($200,000+):        yes / no
Section 503 covered (>$20,000):    yes / no

Ad text
  Veteran statement included:      [ ]
  Disability statement included:   [ ]
  Other EEO wording (client choice / state law): [ ]
  No preference by race, sex, religion, national origin, age: [ ]
  No criminal history questions or "clean record" wording: [ ]
  Pay range, if a state or city law requires it: [ ]

State job bank (VEVRAA)
  Exempt? exec/senior mgmt / internal-only / 3 days or less: [ ]
  Listed with: [state job bank]   Date listed: [ ]
  Listed before or with other sources: yes / no
  Contractor status and priority referral request on file: [ ]

Records
  Copy of each ad and posting date kept with the requisition: [ ]
  Veteran self-identification invitation in the application flow: [ ]

Keep a copy of each ad with the requisition. Job advertisements are hiring records in their own right; the age discrimination rules at 29 CFR 1627.3 list them among the records to keep for a year, and longer retention schedules are covered in how long to keep interview notes.