Yesterday, the Office of Federal Contract Compliance Programs ("OFCCP") published guidance regarding implementation of the agency's new system for federal contractors and subcontractors to enter, track, and submit affirmative action programs ("AAPs"). The OFCCP provided the following implementation timeline for the new system, which the guidance refers to as the OFCCP Contractor Portal (the "Portal").

  • Feb. 1, 2022 – Date on when contractors may begin registering for access to the Portal.
  • March 31, 2022 – Date on when contractors will be able to begin using the certification feature in the Portal to certify their AAP compliance.
  • June 30, 2022  – Date by when existing contractors must certify whether they have developed and maintained an AAP for each establishment and/or functional unit, as applicable.

The Portal was developed after the US Government Accountability Office determined that the OFCCP did not have a system in place to timely ensure that all covered contractors were meeting their obligation to develop and maintain written AAPs. 

Further guidance from the OFCCP regarding the Portal and its application to contractors is forthcoming. For now, however, contractors can view the OFCCP's general Portal information page and Frequently Asked Questions for further information.

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