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What Federal Contractors Need To Know About AAP Requirements


Inevitably, all companies with government contracts will need to go through auditing. Here’s what federal contractors need to know about AAP requirements. To keep workplaces fair and equitable to historically underrepresented minority groups, businesses that work as federal contractors must adhere to and uphold guidelines from the Office of Federal Contract Compliance Programs (OFCCP).

AAP Certification and the OFCCP Portal

Starting this year, federal contractors and subcontractors must certify on the OFCCP Contractor Portal that their affirmative action plans (AAP) meet the standards and guidelines set by affirmative action regulations. Executive Order 11246 created these regulations to ensure historically underrepresented groups get treated fairly and equally within the workplace.

The OFCCP Contractor Portal is an online mechanism created to make the certification process more centralized, secure, and accessible to all federal contractors.

Specifications of Certification

To quote the OFCCP, federal contractors “must certify whether they are meeting their requirements to develop and maintain annual AAPs.”  The OFCCP has yet to give specific guidance regarding what counts as “developing and maintaining,” but this means more than having an affirmative action plan on the shelf. It may also require additional elements such as an annual protected veteran and individuals with disabilities (IWD) self-audit or analysis of compensation systems for race-, ethnicity-, and gender-based disparities. Implementing these required elements of the affirmative action plan are more recent additions to what federal contractors need to know about AAP requirements.

Certifying Without Full Compliance

If you complete your certifications but are not fully compliant in practice, your business can face severe consequences for knowingly making false statements on the certification. Failure to meet your obligations can result in financial penalties, so a bit of outside help can be invaluable to ensuring your business meets every requirement. OFCCP compliance consultants understand the certification processes necessary for your business to meet its obligations and can help you formulate a plan that ensures you cover every critical angle.

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