Hi Jennifer, As you are probably aware, the regulations emphasize that contractors may not compel or coerce individuals to self-identify, and that contractors must keep all self-identification information confidential. However, the regulations are silent on whether a company can require a self-identification form to be returned. The language on the required form written by OFCCP reads, "Completing this form is voluntary, but we hope that you will choose to fill it out." With that language on the form, it appears that the agency's message is that it prefers companies not require a form be returned. Therefore, it is a best practice to use a methodology that leads to more people returning the form than not (e.g. an email versus a pop-up window), and to maintain excellent records to support that the applicant or employee was invited. According to the OFCCP, when resoliciting this information, "Contractors must invite their employees to self-identify every five years, beginning the first year that they become subject to the Section 503 voluntary self-identification requirements. In addition, at least once during the years between these invitations, contractors must remind their employees that they may voluntarily update their disability status at any time." I hope this answers your question. Please reach out if you need additional help.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.