Reminder: Certify compliance by June 30.
The Office of Federal Contract Compliance Programs has gone live today with its Contractor Portal. Contractors can immediately register and update information regarding their organizations and establishments. Starting March 31, contractors can certify compliance with the OFCCP’s regulations requiring development of written affirmative action plans; certification must be completed by June 30.
The OFCCP developed the Contractor Portal as a platform for both contractors and subcontractors to “certify whether they are meeting their requirement to develop and maintain annual AAPs.” Thus, supply and service contractors and subcontractors that meet the jurisdictional thresholds requiring annual affirmative action plans must begin certifying to the OFCCP whether they are in compliance.
The OFCCP has indicated that it intends to use the Contractor Portal to identify for compliance evaluations those contractors that have not developed written AAPs. Not so coincidentally, it will also allow the OFCCP to just identify entities that are contractors and subcontractors in the first place, as this will be the agency’s first central repository of entities that do business with the government and that consider themselves to be contractors.
The OFCCP’s website indicates that further instructions and guides are forthcoming. Covered contractors should remain alert for that additional information.
In the meantime, covered contractors should mark their calendars to ensure the June 30 deadline is met. Presumably, this will be an annual deadline, so the calendar entry should be recurring.
If you have questions about the need to develop written AAPs, please contact any member of Constangy’s Affirmative Action/OFCCP Compliance Practice Group.
PartnerCara co-chairs Constangy’s practice groups relating to EEO/Contractor Compliance, Reporting & Analytics, and DEI Compliance. She advises employers on proactive strategies to help avoid litigation and has defended employers ...
From developments in pay equity and changing requirements in data reporting, to DEI risk mitigation, Title VII compliance, and shifts in enforcement of Section 503 & VEVRAA, the EEO Compliance Dispatch blog is designed to keep employers informed and ahead of the curve.
Whether you’re a federal contractor navigating audits, an HR professional tackling pay transparency, or in-house counsel tracking state and local reporting requirements, our updates, legal analysis, and compliance strategies are tailored to help you manage risk and support a more inclusive workplace.
