FAR 52.222-35 — Equal Opportunity for Veterans

This clause requires affirmative action in employment of protected veterans and prohibits discrimination against them, implementing the Vietnam Era Veterans' Readjustment Assistance Act.

Clause: FAR 52.222-35
Applies to: Contracts over $150,000
Flows down to subs: Yes
Primary risk: VETS-4212 reporting failures

Key takeaways

Read the clause as incorporated in your contract — tailoring and alternates change obligations.
Flowdown obligations are your responsibility; a noncompliant subcontractor is your problem.
Document compliance contemporaneously; after-the-fact reconstruction rarely satisfies auditors.
When a clause is unclear, ask the contracting officer in writing before award, not after.

What the clause requires

Covered contractors must take affirmative action to employ and advance qualified protected veterans, list job openings with the state employment service or another method as required, and file the annual VETS-4212 report disclosing veteran employment data.

How to comply in practice

File VETS-4212 reports on time each year, document job listing practices with the required employment service, and include veteran hiring outreach as part of your standard recruiting workflow.

Common mistakes

Contractors forget the annual VETS-4212 filing because it falls outside typical contract administration calendars, resulting in compliance findings during unrelated audits.

FAQ

What is VETS-4212?

The annual federal contractor report on employment of protected veterans, filed with the Department of Labor.

Who is a protected veteran?

Categories include disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans.

Must job openings be listed externally?

Yes, generally with the appropriate state employment service or another permitted method.