VEVRAA job listing requirements: how federal contractors list openings with the state job bank

As of October 2026, a company holding a federal contract or subcontract of $200,000 or more must list almost every job opening with the state workforce agency job bank, or the local employment service office, where the job is located, no later than it starts recruiting anywhere else. The rule comes from the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) and its equal opportunity clause at 41 CFR 60-300.5, and it survived the 2025 revocation of Executive Order 11246 because it rests on a statute. Executive and senior management jobs, jobs filled only from within, and jobs lasting three days or less are excluded.

This page covers the listing rule itself: who is covered, what to send the state, where to list in Colorado, Washington and Nevada, how OFCCP checks, and the records to keep. The wording that every contractor job ad must carry is covered in job posting requirements for federal contractors, so it is only summarized here.

Who is covered by the VEVRAA listing rule?

The listing duty is part of the equal opportunity clause that goes into covered federal contracts and subcontracts. Under 41 CFR part 60-300 as updated through October 22, 2026:

• Contract threshold: a contract or subcontract of $200,000 or more. The threshold rose from $150,000 to $200,000 on October 1, 2025, under the Federal Acquisition Regulation's inflation adjustment (90 FR 41872), and OFCCP's jurisdictional thresholds page confirms it.
• Indefinite delivery contracts: the clause is included unless the contracting agency expects less than $200,000 to be ordered in any year, and it applies whenever a single order is $200,000 or more.
• Every establishment: the clause covers openings at all of the contractor's establishments, including ones not working on the contract, but not openings at independently operated corporate affiliates.
• Written affirmative action program: a separate duty for contractors with 50 or more employees and a contract of $200,000 or more. The listing rule applies to covered contractors of any size.

What exactly must a contractor list, and when?

Paragraphs 2 to 6 of the clause set the rule. In plain terms:

OFCCP's VEVRAA FAQ adds that the contractor must use whatever submission method the state system requires: if it requires a web form, use the web form; if it accepts email, fax or mail, any of those will do.

The first listing in each state carries extra information

Paragraph 4 of the clause requires the contractor, with its first listing at each state employment service location, to tell the state system that it is a federal contractor and wants priority referrals of protected veterans for openings at all its locations in the state. It must also give the name and location of each hiring location in the state and contact details for the official responsible for hiring at each one. If the contractor uses outside job search organizations, such as a recruiting agency, it must give the state system their contact details too. Changes are sent with the next listing; later contracts do not need a fresh notice.

What is excluded

• Executive and senior management, as the clause defines it: broadly, salaried managers who direct two or more employees and can hire or fire or whose recommendations on that carry weight, or owners of at least a 20 percent equity interest who are active in management.
• Positions filled from within, meaning openings for which no one outside the organization, including affiliates, subsidiaries and parents, will be considered, including recall lists. The exclusion ends the moment the employer decides to consider outside applicants.
• Positions lasting three days or less.
• Openings that occur and are filled outside the 50 states, DC, Puerto Rico and the listed territories.

What changed in 2025 and 2026?

Section 503 of the Rehabilitation Act, now covering contracts of more than $20,000, still requires the disability statement in job ads, but its equal opportunity clause contains no state job bank listing duty. The listing rule is VEVRAA's alone.

Where do you list jobs in Colorado, Washington and Nevada?

Searches for "OFCCP job posting requirements" in these three states usually come from contractors trying to find the right job bank and to square the federal rule with state posting laws. The Department of Labor's CareerOneStop list of state job banks names the systems below. The state rules in the last column are separate from VEVRAA and apply to every posting, contractor or not.

Washington's Employment Security Department says veterans get priority referrals to jobs listed with WorkSource, which is the mechanism the federal rule relies on. For a job that will be filled in more than one state, list it in each state where the opening occurs.

Remote jobs

OFCCP's FAQ treats the place an opening "occurs" as the place the employee reports to work. A fully remote job has no such place, so the contractor may list it with any state or local employment service where qualified candidates are likely to be found. If the posting offers a duty station or remote work, list it where the duty station is, and anywhere else you consider appropriate.

How does OFCCP check that jobs were listed?

Not by reading your careers page. A joint Department of Labor notice, Training and Employment Notice 15-14 (December 11, 2014), explains that during a compliance evaluation or complaint investigation OFCCP contacts the employment service staff at the American Job Center the contractor uses and asks for the job orders the contractor placed, by job title and date. It then compares that list with the jobs the contractor filled through new hires, identifies any not listed, and decides whether they should have been. State agencies must provide this information under 41 CFR 60-300.84.

The practical consequence: every external hire should match a state job order with an earlier or same-day date, unless it falls into an exclusion you can document.

What records should a contractor keep?

• Job ads and postings, applications, resumes and interview notes: kept for two years under 41 CFR 60-300.80, or one year if the contractor has fewer than 150 employees or no contract of at least $200,000. See how long to keep interview notes.
• Proof of each state listing: the confirmation or job order number and the date, kept with the requisition. Nothing else shows "at least concurrently."
• Data collection analysis (contractors with an affirmative action program): each year, the number of job openings, jobs filled, applicants, protected veteran applicants and hires, kept for three years. OFCCP's FAQ counts openings by position, not by requisition: one requisition for five positions that produces four hires is five openings and four jobs filled.
• Exclusion decisions: a note on any requisition treated as internal-only or executive, with the reason. Applicant counting for the same records is covered in the Internet Applicant rule.

The separate VETS-4212 report on veteran employees and new hires is due each year on September 30, according to the Department of Labor's Federal Contractor Program page.

What should a recruiter or agency do on a contractor's requisition?

1. Ask at intake whether the role sits with a federal contractor at or above $200,000 and in which state the job occurs. Write the answer on the job order.
2. Check the exclusion honestly. If the client says "internal only," confirm no outside candidate will be considered; once an agency is engaged, that is rarely true.
3. Get the state listing confirmation before you post or source. Your job board post going live first can put the client out of compliance, because the listing must be at least concurrent.
4. Expect to be named. The clause asks the contractor to give the state system contact details for outside job search organizations it uses, so the state may know your agency is recruiting for the client.
5. Accept state referrals. A listing is a bona fide job order. Screen referred candidates on the same criteria as everyone else and record the outcome.
6. Use the client's ad wording for the veteran and disability statements, word for word; the wording rules are in job posting requirements for federal contractors.

A listing checklist for one requisition

VEVRAA LISTING CHECK - [role] - [req #] - [date]
Contract value $200,000 or more (or single order):  yes / no
State(s) where the opening occurs:                  [ ]
Remote? Duty station offered?                       [ ]

Exclusions (tick one or none)
  Executive / senior management (per clause):       [ ]
  Filled from within, no outside candidates:        [ ]
  Lasts three days or less:                          [ ]

State job bank
  System: Connecting Colorado / WorkSourceWA / EmployNV / other: [ ]
  First listing in this state? Contractor status, priority referral
  request, hiring locations, hiring contact, agency contacts sent: [ ]
  Job order number: [ ]   Date listed: [ ]
  Listed before or with every other source:          yes / no

Records
  Copy of each ad and posting date with the requisition: [ ]
  Openings counted by position for the annual analysis: [ ]