Federal Contractors (And Subs) To Certify Affirmative Action Program Compliance Starting March 31

Federal contractors and subcontractors will soon be required to certify, on an annual basis, to the Office of Federal Contract Compliance Programs ("OFCCP") that they have developed and maintained a written affirmative action program ("AAP"). On February 1, 2022, registration opened for the OFCCP AAP Verification Interface ("AAP-VI" or "Contractor Portal") and, on March 31, the certification features will be turned on. When the certification features become available, existing covered contractors will then have until June 30, 2022 to certify that they have developed and maintained their AAPs. ¹

Briefly, federal supply and service prime contractors and subcontractors have long been required, under Executive Order 11246 and Section 503 of the Rehabilitation Act of 1973, to develop AAPs for each establishment where they have 50 or more employees and at least one contract (or subcontract) that is greater than $50,000. Further, under the Vietnam Era Veterans'