The site that allows employers to file the annual VETS 4212 report is now open. The report, which is required by the Veterans and Employment Training Service (VETS), must be filed by September 30, 2020.

Federal contractors and subcontractors that have a single contract of $150,000 or more must file the VETS 4212 report. In the report, employers must provide information on both employees and hires. Information on employees must be provided within EEO-1 categories while information on hires can be reported either within EEO-1 categories or in an aggregated form. For both employees and hires, employers must provide information on all persons who are protected veterans.

Multi-facility employers must file VETS 4212 reports for all establishments that have more than 50 employees. VETS has certain rules about how smaller establishments can be consolidated. The VETS 4212 FAQs indicate that employers with subsidiaries must file VETS 4212 reports for all subsidiaries that have a federal contract or subcontract of $150,000 or more.

The regulations regarding the VETS 4212 report state that employers must file reports between August 1, 2020 and September 30, 2020. However, it is not unusual for the VETS 4212 reporting period to be extended. While VETS is currently indicating that it will stand by the September 30 reporting deadline, it is possible the COVID-19 pandemic will result in an extension. For the moment, employers should plan to report by September 30.

OFCCP asks for a copy of the VETS 4212 report at the start of every traditional compliance review and is required to contact VETS if the report has not been filed. In an odd quirk, the letter that opens a review focused on compliance with the affirmative action law for veterans does NOT ask for a VETS 4212 report.