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AAP Compliance Certification Portal Guidance

As we previously reported, the Office of Federal Contract Compliance Programs (OFCCP) was in the process of launching a new Contractor Portal (Portal) which requires federal contractors and subcontractors (“contractors”) to certify the compliance of their affirmative action plans (AAPs). The Portal has been launched and opened on February 1, 2022. Between February 1 and March 30, 2022, the Portal will be open for registration only. The Portal will not allow actual certification until March 31.

Portal Information and Tips for Use

To enhance the registration process, the Portal pre-populates existing contractor establishment data from the 2018 EEO-1 report. To use this feature, contractors enter the information from the 2018 EEO-1 report into the Portal fields “Headquarter/Company Number,” and “Establishment/Unit Number” during the registration process to help access company records.

OFCCP has also provided the following tips about this feature to help contractors with the registration process:

  • Enter only the first six digits of the 2018 EEO-1 identifiers when completing the fields “Headquarter/Company Number” and “Establishment/Unit Number.” Each identifier you enter must be a six-digit number. If an EEO-1 identifier has more than six digits, enter only the first six digits of the number.
  • Enter EEO-1 identifiers from the 2018 EEO-1 report only. The Contractor Portal’s registration process is configured to work only with information from the 2018 EEO-1 report. At this time, no other versions of the EEO-1 report are supported.
  • If you have filed a 2018 EEO-1 report and attempted to register using only the first six digits of the 2018 EEO-1 identifiers for the “Headquarter/Company Number” and “Establishment/Unit Number” fields and receive an error, please contact the Contractor Portal Technical Help Desk for assistance through the OFCCP Contractor Portal Technical Help Request Form. Do not attempt to register for the portal using the “Identifiers Not Known Path,” as this will result in the portal account not being matched to the company records in the system and data for your company will not pre-populate.
  • Parent Companies who did not file a 2018 EEO-1 report, universities, or other federal contractors or subcontractors who have not received any invitation from OFCCP to register still can register and add records for establishments or functional/business units. The only identifier required to register for the Contractor Portal is the Employer Identification Number (EIN). Where there is no EEO-1 information, register using the “Identifiers Not Known Path.” To complete registration for the Contractor Portal without 2018 EEO-1 identifiers, please follow the instructions for the “Identifiers Not Known Path” in the OFCCP Contractor Portal User Guide.

Of note, construction contractors will not be required to register in the portal or certify AAP development because they are not required to prepare written AAPs under Executive Order 11246.

Next Steps for Employers

Employers should ensure that registration has been complete by March 30, 2022. Employers may refer to the OFCCP Contractor Portal Landing Page to access the Contractor Portal FAQs and the OFCCP Contractor Portal User Guide for detailed instructions on completing the registration process.

How HR Works Can Help

Current HR Works AAP clients will be notified of the support HR Works can provide in utilizing the portal and should contact their HR Works project manager with questions.

This new certification process heightens OFCCP’s focus on organizations that are out of compliance. If your organization is new to AAP development and in need of assistance, our affirmative action specialists are here to help. Contact us today at info@hrworks-inc.com, or 1-877-219-9062.

HR Works, Inc., headquartered at 200 WillowBrook Office Park in Fairport (Rochester), New York, with an office in East Syracuse, is a human resource management outsourcing and consulting firm serving clients throughout the United States. HR Works provides scalable strategic human resource management and consulting services, including: affirmative action programs; benefits administration outsourcing; HRIS self-service technology; full-time, part-time and interim on-site HR managers; HR audits; legally reviewed employee handbooks and supervisor manuals; talent management and recruiting services; and training of managers and HR professionals.