Affirmative Action Plan (AAP)

What Is an Affirmative Action Plan (AAP)?

An affirmative action plan (AAP) is a plan or program that outlines a federal contractor or subcontractor’s efforts to provide equal employment opportunities and generally support the advancement of employees regardless of gender, race, disability, or veteran status.

Affirmative Action Plan Requirements

Formal affirmative action plans are only required for federal contractors and subcontractors.

There are additional conditions set forth by the Office of Federal Contracts Compliance Programs (OFCCP), which oversees federal contractor compliance. Their conditions include all non-construction federal contractors or subcontractors who:

Check with the OFCCP if you meet these conditions.

Affirmative Action Compliance

AAPs are monitored by the OFCCP at the federal level and must be updated in its online contractor portal annually. Multiple users from each organization can register on the portal to manage records if needed. Contractors that don’t certify their AAPs annually are more likely to be audited by the OFCCP.

Some states have additional AAP compliance requirements. Check with your state’s Department of Labor or Employment’s exact specifications.

In addition to having a written, up-to-date plan, the OFCCP also recommends keeping records as evidence of its affirmative action efforts, such as:

AAP Reporting

According to the OFCCP, contractors should employ internal audits and reporting systems to keep track of relevant employee demographic information, monitor anti-discrimination initiatives, and analyze the effectiveness of any affirmative action plan.

Information to collect includes:

To be clear, an AAP is the written document of the plan and policies that will guide the company forward over the next year, not the audit or reporting system that the company uses. However, it relies on the results and data collected from both.

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