5. 26. 22

New Affirmative Action Plan Certification Guidelines


Federal contractors and subcontractors who are required to develop and maintain an Affirmative Action Plan (AAP)  now need to register and certify their plans on an annual basis through a new online portal.

On February 1, 2022, the Office of Federal Compliance Programs (OFFCP) launched its new Contractor Portal. Through this portal, federal non-construction contractors and subcontractors must register and certify on a yearly basis that they have developed and are maintaining an Affirmative Action Plan.

The Portal was developed after the OFFCP proposed it in 2018 as a means to improve and increase AAP compliance.

Covered contractors will have until June 30, 2022 to register their company and certify that they have developed and maintained an AAP for each established location.


What is an Affirmative Action Plan, and Who is Required to Have One?

An AAP is a program that outlines an employer’s efforts to provide equal employment and advancement opportunities to individuals within protected classes, including women, minorities, disabled individuals and veterans.

An AAP differs from the Equal Employment Opportunity (EEO) requirements set forth by the Equal Employment Opportunity Commission (EEOC).

Whereas nearly all employers are required to comply with EEO laws and regulations, only federal contractors and subcontractors with 50 or more employee and a contract valued at $50,000 or more are required to develop and maintain an Affirmative Action Plan.

Unsure whether you need an AAP? For a full list of AAP coverage requirements, click here.


How Should Employers Prepare for Certification?

The Contractor Portal opened on February 1. Since then, contractors have been able to access the portal to register their business. To register for the Portal, contractors will need data from their 2018 EEO-1 reports.

The OFFCP is strongly recommending that covered contractors register for the Portal by no later than March 30, 2022.

Beginning March 31, contractors will then have until June 30, 2022 to certify their AAP compliance. Those contractors who fail to certify their AAP in a timely manner, or at all, will be more likely to be selected for a compliance audit from the OFFCP.

For additional information on the Contractor Portal registration and certification process, please visit the OFFCP’s Contractor Portal FAQs.


How XpanseHR Can Help

To determine if your company needs an AAP, or to learn how XpanseHR can help with AAP development and compliance, contact us at or 610-614-5500.