From the information you offered, it does appear that the contract would be covered under EO 11246. This is what the OFCCP has posted on their website: Executive Order 11246 applies to federal construction contractors that meet one or more of the following contract thresholds: A direct federal construction contract or subcontract of over $10,000. A federally assisted construction contract or subcontract of over $10,000. Two or more federal construction contracts or subcontracts of less than $10,000 that, when added together, total more than $10,000 within any 12-month period or can reasonably be expected to total more than $10,000 during that time. A construction contract or subcontract of over $10,000 with a federal nonconstruction contractor or subcontractor, if the construction contract/subcontract is necessary in whole or in part to the performance of the federal nonconstruction contract or subcontract or if the subcontractor performs, undertakes or assumes any portion of the contractor’s obligation. When do Section 503 of the Rehabilitation Act of 1973 (Section 503) and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA) apply to federal construction contractors? Section 503 applies to federal construction contractors with a direct government contract more than $15,000. The OFCCP published the Construction Technical Assistance Guide which outlines the requirements for companies with a federal construction contract or federally assisted construction contract at https://www.dol.gov/sites/dolgov/files/ofccp/Construction/files/ConstructionTAG.pdf.