If you hold a single federal contract worth $200,000 or more, you owe the Department of Labor a headcount report by September 30 — and nobody is going to remind you. The Veterans' Employment and Training Service (VETS) sends no emails about the filing window, no deadline warnings, and no overdue notices. The 2026 platform opened August 1, and contractors who miss the date find out the expensive way: when the Office of Federal Contract Compliance Programs (OFCCP) asks for proof of filing during an audit.
This guide covers who must file, what data goes in the report, how multi-location employers handle it, and what happens if you skip it.
Who Must File: One Contract, $200,000, Any Headcount
You must file a VETS-4212 report if you are a nonexempt federal contractor or subcontractor with a single covered contract or subcontract of $200,000 or more. Three things about that trigger surprise small businesses:
It is one contract, not total federal revenue. Two $120,000 contracts do not trigger the duty; one $200,000 contract does. Check your largest single award, including modifications that pushed it over the line.
Employee count is irrelevant. Unlike EEO-1 reporting, which generally starts at 100 employees, VETS-4212 applies regardless of workforce size. A five-person subcontractor with one qualifying award files the same report as a 5,000-person prime.
The threshold used to be $150,000. The Federal Acquisition Regulatory Council raised it to $200,000 through its inflation adjustment of acquisition thresholds. If you filed in past years on a contract between $150,000 and $200,000, confirm you still have a qualifying award before assuming you are covered — and if your only contract sits just under $200,000, you are off the hook this cycle.
A "covered" contract means procurement of personal property or nonpersonal services from any U.S. department or agency — including utility, construction, transportation, research, insurance, and fund-depository agreements. Banks and FDIC-insured institutions are covered too when a single agreement meets the threshold, including agreements to serve as federal fund depositories or as issuing and paying agents for U.S. savings bonds.
One timing rule matters for newcomers: entering into a covered contract during a calendar year creates the filing duty the following year. If you won your first qualifying contract in 2026, your first VETS-4212 is due in the 2027 cycle — but if you held one at any point in 2025, you file now.
What Data Goes in the Report
The form has two data sections per reporting location, and both come straight from your payroll and HR records.
Workforce snapshot: protected veterans vs. total employees, by job category. Column A reports the number of protected veterans and Column B the total number of employees, each broken across the same ten EEO-1 occupational categories (executive/senior-level officials and managers, first/mid-level officials and managers, professionals, technicians, sales workers, administrative support, craft workers, operatives, laborers and helpers, and service workers). If you already map employees to EEO-1 categories, reuse that mapping.
Hiring activity: the last 12 months, no category breakdown. Column C reports protected-veteran hires and Column D reports total hires during the 12-month period preceding your chosen payroll-period ending date. Unlike the snapshot, hires are reported as location-wide totals.
Company identification and location details. The top of the form carries your company identifiers, the reporting location, and the maximum and minimum employee counts during the reporting period.
The Four "Protected Veteran" Categories
"Protected veteran" is a defined term under the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA). It covers four groups:
- Disabled veterans — entitled to VA disability compensation (or discharged because of a service-connected disability).
- Recently separated veterans — within three years of discharge or release from active duty.
- Active duty wartime or campaign badge veterans — served on active duty during a war or in a campaign or expedition for which a campaign badge was authorized.
- Armed Forces service medal veterans — awarded an Armed Forces service medal while on active duty.
You report one aggregate protected-veteran number, not a per-category breakdown. But the categories still matter for data collection: "recently separated" status expires three years after discharge, so an employee counted as a protected veteran last year may drop out of the count this year. If your self-identification records do not capture discharge dates, you cannot maintain the count accurately year over year.
Multi-Location Employers File More Than One Report
Single-location contractors file one report through the web-based system. If you operate at more than one hiring location, the rules branch:
- File one report covering the principal or headquarters office.
- File a separate report for each hiring location employing 50 or more people.
- For locations under 50 people, file either separate reports per location or one consolidated report per state covering those smaller locations.
Filing method follows location count. Contractors with more than 10 locations must submit electronic data files (each state-consolidated report counts as one location); those with 10 or fewer may still file on paper. Electronic filing through the VETS web-based system is the preferred method either way, with batch upload, mail, courier, and email-attachment options spelled out in the form instructions. Start at the DOL's VETS-4212 reporting page, which links the current filing system and specifications.
Why OFCCP Cares About a Form You File With VETS
VETS administers the report, but OFCCP enforces the ecosystem around it. During a compliance evaluation, OFCCP checks the companion VEVRAA obligations — including whether you filed your VETS-4212 and whether you list job openings with the state workforce agency as the mandatory job-listing rule requires. A missing filing is a standalone violation it can pursue through conciliation, and VEVRAA sanctions run up to contract cancellation, suspension or termination, withholding of progress payments, and debarment from future federal work.
The report data also feeds the broader affirmative-action picture. VEVRAA requires covered contractors to maintain a written affirmative action program for protected veterans, track applicant and hire data, and measure hiring against OFCCP's annual hiring benchmark. The VETS-4212 numbers should reconcile with the hires your AAP records show — an auditor who finds the two telling different stories will ask which one is wrong.
Context for 2026: while other federal employment reports face rollback pressure, VETS-4212 survived intact — the platform opened on schedule August 1. And just days before the deadline, OFCCP's Section 503 final rule took effect on September 21, stripping the disability utilization-goal analyses from AAPs while leaving written plans and the veterans' obligations untouched. If you were hoping the veterans' report would quietly disappear with the disability paperwork, it did not.
Three Mistakes That Invite Follow-Up Questions
Counting stale "recently separated" veterans. This is the only protected category with an expiration date, and the most common source of inflated counts. An employee discharged in 2022 belonged in the protected column for the 2023–2025 cycles and drops out for 2026. Without discharge dates in your records, you cannot age anyone out — so the count only ever grows, which is exactly the pattern that makes an auditor ask for backup.
Pulling the snapshot and the hires from different dates. The headcount columns describe one payroll-period ending date; the hiring columns describe the 12 months ending on that same date. Contractors in a rush sometimes report current headcount alongside calendar-year hires, producing a report whose parts describe different workforces. Pick the date first, then pull both numbers from it.
Forgetting the small locations. Multi-establishment employers remember headquarters and the big sites, then overlook the under-50-person locations entirely — neither separate reports nor a state-consolidated one. Enumerate every hiring location before you start filing, and decide the per-state consolidation up front.
A Five-Day Sprint Plan (and Next Year's System)
With September 30 only days away, work backward from the deadline:
- Confirm coverage today. Pull your largest single federal contract or subcontract, including modifications. At or above $200,000, you file. Below it, document why you sat this year out so next year's team does not guess.
- Lock your reference date. Choose the payroll-period ending date for the snapshot and pull headcount as of that date plus hires for the 12 months before it. Use the same payroll system export for both so the numbers tie.
- Scrub the veteran self-ID data. Verify discharge dates for everyone flagged as recently separated — anyone past the three-year mark comes out of the protected count. If self-ID records are thin, file on the best data you have and fix collection going forward; a good-faith complete filing beats a late one.
- Map to EEO-1 job categories. Borrow your EEO-1 mapping if you have one; if not, assign each employee once and save the crosswalk for next year.
- File electronically and keep the confirmation. E-file through the VETS system, download the acknowledgment, and store it with your AAP records. Then calendarize August 1 of next year — because VETS will not remind you.
For next year, the durable fix is process, not heroics. Add veteran self-identification to onboarding, re-survey the workforce on a schedule, and reconcile protected-veteran hires to payroll quarterly instead of reconstructing them every September.
Keep Your Headcount Data Audit-Ready All Year
VETS-4212 is ultimately a test of whether your employment records can answer a precise question on demand: how many people worked here, in what roles, who was hired, and how many were protected veterans. Contractors who scramble every September usually have the same underlying problem — headcount, hires, and job categories living in three different systems that nobody reconciles until a filing forces the issue.
That is a bookkeeping discipline as much as an HR one. When payroll records, new-hire logs, and job-category mappings tie to the same ledger every month, the September filing becomes an export rather than an excavation — and the numbers you report will match the numbers an auditor finds. Beancount.io provides plain-text accounting that gives you complete transparency and control over your financial and workforce data — no black boxes, no vendor lock-in. Get started for free and see why developers and finance professionals are switching to plain-text accounting.
