Affirmative Action Plans

Government contractor? You may be required to prepare an AAP.

Does this describe your company?

Government Contractor



$50k or higher


If so, your business is legally required to annually prepare an AAP.

Failure to Comply considered a violation of the government contract!

The Department of Labor’s Office of Federal Contract Compliance Program (OFCCP) has the authority to audit your company or disbar them from government contracts for up to seven years. Not sure where your company stands? Let us help.

What does an audit look like? Is my company compliant?

Stay Compliant with the Law.

It's The Law:

Under federal law, government contractors and subcontractors with 50 or more employees who have entered into at least one contract of $50,000 or more with the federal government must prepare and maintain a written affirmative action program, which must be developed within 120 days from the commencement of the contract and must be updated annually.

"...must be developed within 120 days and updated annually."

John . Kennedy

Created in 1961, changes as recent as 2014.

First signed by President John F. Kennedy, the first iteration of AAP required that government contractors "take affirmative action to ensure that applicants are employed, and employees are treated during employment, without regard to their race, creed, color, or national origin"

Over the years ammendments have been passed. Discrimination based on sex is prohibited and recently new regulations were passed in 2014 that require identification and an evaluation of the company’s good faith efforts to recruit protected veterans and disabled individuals. This obligation will necessitate the contractor to list all of the recruiting efforts the company made during the calendar year, time period to recruit veterans and disabled individuals — along with an evaluation of the effectiveness of each effort.

Executive Order 11246

Prohibits discrimination on the basis of race, color, religion, sex, or national origin.

Learn more

Rehabilitation Act of 1973

Prohibits discrimination on the basis of disability.

Learn more

Vietnam Era Veterans Readjustment Assistance Act of 1974 (VEVRAA)

Prohibits discrimination against certain classes of veterans.

Learn more

Your company may be susceptible to a compliance review

The compliance review may progress in three phases:

A Desk Audit

On-site Review

Off-site Analysis

OFCCP describes the phases of a compliance review in its regulations at 41 CFR CHAPTER 60.

Failure to Comply

Failure to comply with the non-discrimination or affirmative action provisions is considered a violation. The Department of Labor’s Office of Federal Contract Compliance Program (OFCCP) is the agency with authority to enforce these laws by auditing a company’s AAP's and employment practices which could result in potential disbarment for seven years.

In every OFCCP audit, the Compliance Officer will request to review the current year AAP and the previous two year's AAP.

It is extremely important to ensure that all AAP's are properly updated each year and retained.