AFFIRMATIVE ACTION PLANS: Are You Ready or Are You at Risk?


Each year the OFCCP conducts compliance reviews of AAPs, or audits, as part of their efforts to enforce affirmative action regulations. An employer has 30 days to submit the requested materials to the OFCCP upon notice of a compliance review.

Are you prepared to respond if you are selected for an audit?

Employers will soon be required to proactively verify with the OFCCP that they have written their required annual AAP(s), and those who don’t may have an increased probability of being audited. The OFCCP may also request that employers upload a copy of their plan(s) as part of this verification.

Do you currently have a written affirmative action plan on file, and is it being maintained?

When conducting a compliance review, the OFCCP may focus on specific areas such as compensation, recordkeeping, outreach, and other regulations. It is important for employers to update their plans on an annual basis in order to demonstrate their efforts.

In 2020, 37% of compliance evaluations completed by the OFCCP resulted in violations or conciliation agreements.

The risks of non-compliance include:

  • Negative publicity
  • Recruitment challenges
  • Employee relations issues
  • Hiring or training mandates
  • Higher risk of discrimination lawsuits
  • Loss of current contracts
  • Financial remedies
  • Additional data tracking and reporting requirements (conciliation)
  • Debarment from future contracts


With over 30 years of experience and nationally recognized attorneys on retainer, HR Works offers clients more than just an AAP, we offer peace of mind.

Our clients know that their AAP is audit-ready, 100% technically compliant, and backed by a team of consultants who will provide support throughout the audit process.

Have confidence in your compliance. Choose HR Works for your AAP needs.

We are here to help. Contact us today!