Quick Hits

• All 2025 VETS-4212 filings are due by September 30, 2025.
• Federal contractors and subcontractors with a single covered contract of $150,000 or more are required to file VETS-4212 reports.
• There are indications that the VETS-4212 platform is experiencing technical issues that could impact filers, especially those that file larger numbers of reports.

Who must file VETS-4212 reports?

Federal contractors or subcontractors with a single contract of $150,000 or greater, regardless of the number of employees, are required to file VETS-4212 reports. The U.S. Department of Labor’s (DOL) Veterans’ Employment and Training Service’s (VETS) frequently asked questions (FAQ) guidance states that the contract or subcontract may be with “any department or agency of the United States” and includes procuring personal property and services such as “utility, construction, transportation, research, insurance, and fund depository.” The FAQs state that this filing requirement applies to banks, financial institutions, or private sector entities insured by the Federal Deposit Insurance Corporation (FDIC) if a single contract meets the dollar threshold. Federal contracts can include “agreements to serve as fund depositories, agreements for federal share and deposit insurance, and agreements to serve as an issuing and paying agent for U.S. savings bonds and savings notes.”

What data must be filed?

The single-page VETS-4212 form is split into two data sections for the reporting location. On the left side of the form, Column A shows the total number of protected veterans broken down into the ten EEO-1 occupational categories, and Column B shows the total number of employees in each of the ten EEO-1 occupational categories. The right side of the data section shows hiring activity for the report location for the last twelve months, including the total number of protected veteran hires during the previous twelve months in Column C and the total number of hires in Column D. The form does not require that hiring activity be broken down by EEO-1 occupational category. The upper part of the form contains company identification information and information on the location for which the VETS-4212 form is being filed. The VETS-4212 reporting process still requires contractors to provide DUNS numbers as part of the filing, unlike the EEO-1 reports, which utilize Unique Entity Identifier (UEI) numbers.

What are the technical issues that some filers have experienced and what is their impact?

There are reports of filers being unable to upload batch files through the filing platform. Batch files are used to file multiple individual reports using a single data file. The FAQs state that companies with more than ten hiring locations are encouraged to use the batch upload process to “expedite processing.” Filers can also manually input their data into the filing system, but there can be substantial time savings using the batch files when filing large numbers of reports. If filers are unable to upload batch files, they can manually enter the data, which for large filers could require significant additional time and personnel resources. Filers can also contact VETS to request assistance with the batch uploads.

There are also indications that the “Download All Reports” button in the filing platform has not been consistently working. This button allows filers to download all filed reports into a single PDF through the click of one button. Filers also have the option to download each filed report individually. While the loss of the download all function is not a major concern for a filer with a small number of reports, it can become an issue for a filer with fifty, one hundred, or several hundred reports, as downloading a substantial number could require significant additional time. While downloading filed reports is not necessarily required as the filing platform maintains copies of filed reports, many filers use the downloaded reports to review the filings and save the downloaded reports as PDFs as a record of their filings. If this issue persists, it could mean that filers with numerous locations will have to either spend substantial amounts of time manually downloading individual reports or complete their report review in the filing platform without saving copies of their filed reports.

Based on the upcoming filing September 30 deadline and reports of filing platform technical issues, covered government contractors and subcontractors may want to consider preparing now so they can complete their required filings by the September 30, 2025, deadline.