--- title: What is an affirmative action plan? An Employer’s Guide To Compliance description: Is your company required to maintain AAP compliance? If you’re a federal contractor, learn more about affirmative action plans to see if you must comply. image: https://www.completepayrollsolutions.com/hubfs/Affirmative%20Action%20Plan.jpg --- [![CPS Logo_rgb-2](https://www.completepayrollsolutions.com/hubfs/CPS%20Logo_rgb-2.svg "CPS Logo_rgb-2")](https://www.completepayrollsolutions.com) - Solutions - - [Payroll Payroll tax filing, automated and integrated processing, paperless reporting and more.](https://www.completepayrollsolutions.com/payroll-outsourcing) - [Talent Management Personalized recruiting, onboarding, performance management, training and offboarding.](https://www.completepayrollsolutions.com/talent-management) - [HR Solutions HR support, handbook development, training, safety and compliance — all the daily tasks of people management.](https://www.completepayrollsolutions.com/hr-outsourcing) - - [Benefits Comprehensive and affordable medical, dental, retirement, workman’s comp and pre-tax savings plans.](https://www.completepayrollsolutions.com/employee-benefits) - [Time & Attendance Integrated time and attendance tracking, PTO request and accrual management, scheduling and reporting.](https://www.completepayrollsolutions.com/time-and-attendance) - [Employee Engagement Custom experiences designed to attract, engage, and retain talent to get the best from your staff.](https://www.completepayrollsolutions.com/employee-engagement) - - See How It Works - ![Executive Dashboard](https://www.completepayrollsolutions.com/hs-fs/hubfs/2021%20Website%20Update%20Images/Images/Nav-Demo-Thumbnail.png?width=250&name=Nav-Demo-Thumbnail.png) - [![Request a Demo](https://no-cache.hubspot.com/cta/default/1885176/b949a8d0-722d-43f0-bed8-a62983a06b31.png)](https://resources.completepayrollsolutions.com/demo-request) - Who We Serve - - [Startups Start strong with personal service that will grow with you as you scale your business.](https://www.completepayrollsolutions.com/payroll-and-hr-startups) - [Small & Medium Businesses Grow and evolve with strategic guidance and all-in-one solutions for payroll, HR and benefits.](https://www.completepayrollsolutions.com/small-medium-business-payroll-benefits) - [Large & Enterprise Businesses Discover custom systems and integrations with industry-leading technology to help reduce administrative burden and increase your bottom line.](https://www.completepayrollsolutions.com/payroll-and-hr-outsourcing-large-business) - - [Industries Get an experienced partner with the insider info you need to stay compliant and ahead of the curve.](https://www.completepayrollsolutions.com/who-we-serve) - [Our Partners Close relationships with top-tier companies within their industries.](https://www.completepayrollsolutions.com/partnerships) - Resources - - [Blog Smart articles and lots of answers to your most asked questions.](https://www.completepayrollsolutions.com/blog) - [Learning Center In-depth resources designed to make your payroll, HR, and benefits experience easier.](https://www.completepayrollsolutions.com/resources) - [Employee, Federal & State Forms Up-to-date documents and links at your fingertips.](https://www.completepayrollsolutions.com/employee-federal-state-forms) - - [Tax Guide & Calendar](https://www.completepayrollsolutions.com/hubfs/2023TaxCalendar_FINAL_20230103.pdf) - [![Tax Guide & Calendar](https://www.completepayrollsolutions.com/hs-fs/hubfs/2023%20Tax%20Calendar%20Image.png?width=200&name=2023%20Tax%20Calendar%20Image.png)](https://www.completepayrollsolutions.com/hubfs/2023TaxCalendar_FINAL_20230103.pdf) - Who We Are - - [Contact Speak with an industry expert or connect with your CPS Consultant.](https://www.completepayrollsolutions.com/contact-us) - [About Us CPS is your *people partner*. Find out what that means.](https://www.completepayrollsolutions.com/about-us) - - [Careers Join CPS and become one of our people.](https://www.completepayrollsolutions.com/careers/) - [Data Security & Privacy Details about how we protect the privacy of your business and employees.](https://www.completepayrollsolutions.com/data-security) - [CPS Data Events](https://www.completepayrollsolutions.com/hubfs/2025-announcements/cps-web-notification-event-20250310%5B87%5D.pdf) - [Contact](https://www.completepayrollsolutions.com/contact-us) - [Login](https://www.completepayrollsolutions.com/portal) [Home](https://www.completepayrollsolutions.com/) / [HR](https://www.completepayrollsolutions.com/blog/topic/hr) / What is an affirmative action plan? An Employer’s Guide To Compliance # What is an affirmative action plan? An Employer’s Guide To Compliance by [Karyn H. Rhodes | SHRM-SCP, SPHR](https://www.completepayrollsolutions.com/blog/author/karyn-h-rhodes-shrm-scp-sphr) on Jul 27, 2023, 9:26:32 AM [![A group of people in an office work independently at their individual desks.](https://www.completepayrollsolutions.com/hs-fs/hubfs/Affirmative%20Action%20Plan.jpg?width=500&name=Affirmative%20Action%20Plan.jpg)](https://www.completepayrollsolutions.com/blog/what-is-an-affirmative-action-plan) As a federal contractor or subcontractor, you know you’re subject to some additional rules and need to take extra steps to keep your workplace compliant. One of the things you need to do is have an affirmative action plan to ensure equal employment opportunities. Just what is a plan and what do you need to do to meet the requirements? Let’s find out. In this article, we’ll explain what an affirmative action plan is, when one is required, and tips on how to create a plan for your organization. After reading this, you’ll know if you’re subject to the affirmative action plan requirements and how to best follow them. ## What is an affirmative action plan? An affirmative action plan, or AAP, is a written program that details the steps an employer has taken and will take to ensure equal employment opportunities in terms of recruitment and selection, advancement, and other privileges, without regard to race, color, religion, sex, sexual orientation, gender identity, or national origin. It should not only outline how an organization will consistently promote affirmative action through its policies and programs but also how it will track specific affirmative action metrics. While required by federal contractors and subcontractors to provide more opportunities for underemployed populations and help eliminate discrimination, even some organizations that are not required to have an affirmative action plan choose to have strong diversity equity and inclusion (DEI) programs to promote greater equality in the workplace. For the purposes of this article, we’ll focus on required versus voluntary plans. ## When is an affirmative action plan required? An affirmative action plan is required by contractors that have at least 50 employees and at least 1 contract valued at the[jurisdictional threshold amounts](https://www.dol.gov/agencies/ofccp/jurisdictional-thresholds#Q2) as follows: - [**Executive Order 11246**](https://www.ecfr.gov/current/title-41/subtitle-B/chapter-60/part-60-2): A contract of $50,000 or more. This order applies to non-construction (supply and service) contractors and prohibits federal contractors from discriminating on the basis of race, color, religion, sex, sexual orientation, gender identity, or national origin. - [**Section 503**](https://www.ecfr.gov/current/title-41/subtitle-B/chapter-60/part-60-741) **of the Rehabilitation Act of 1973, as amended (Section 503)**: A contract of $50,000 or more. This clause, which applies to both construction and non-construction contractors, prohibits discrimination against individuals with disabilities and requires contractors and subcontractors to take affirmative action to employ and advance in employment qualified individuals with disabilities. - **Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended (VEVRAA)**: A contract of $150,000 or more. This regulation covers construction and non-construction contractors and is intended to prohibit discrimination against protected veterans. It’s important to note that section 503 and VEVRAA don’t apply to federally-assisted construction contractors and subcontractors; however, they do apply to direct federal construction contractors and subcontractors. ## What affirmative action employer requirements are there? If you are a covered employer, you’ll need to take several steps to stay in compliance with affirmative action plan requirements. 1. **Write and maintain an AAP**. You’ll need to develop a written AAP within 120 days of entering a federal contract or subcontract. The Department of Labor (DOL) offers[sample AAPs](https://www.dol.gov/agencies/ofccp/compliance-assistance/sample-affirmative-action-programs) but they should be customized to reflect your organizational structure, policies, practices, programs, and data. 2. **Analyze data and develop action plans for underutilization**. Companies must review the number and percentages of minorities and women each year compared to the relevant labor pool, identify problem areas, and establish action-oriented goals to address any underutilization. 3. **Review your plan obligations at least once a year** with supervisory personnel and employees responsible for hiring, termination, and other employment-related decisions before work begins on job sites. 4. **Register and certify that you are developing and maintaining annual affirmative action plans in a**[**contractor portal**](https://www.dol.gov/agencies/ofccp/contractorportal). AAP reporting requirements state that you must complete this certification for each establishment or functional/business unit annually. If you certify that you don’t have a plan or don’t complete the certification at all, it may increase the likelihood of an OFCCP audit. The Office of Federal Contract Compliance Programs (OFCCP) is responsible for ensuring compliance with affirmative action requirements, and may conduct audits or on-site inspections, where they request your affirmative action plan and supporting data. Penalties for failing to meet your federal contractor requirements can include both monetary penalties as well as being barred from future government contract work. ## How do you write an affirmative action plan? The requirements for your AAP will differ based on the governing law that covers your business, with some common elements between them. - **Executive Order 11246**: You’ll want to include: - **Section 503**: For the plans required to prevent discrimination against individuals with disabilities, your plan should include: - **VEVRAA**: To ensure equal opportunities for protected veterans, your plan should include: It’s important to note that any of the required plans should be updated annually based on the data from the previous year and include steps the company will take the next year. For example, if you’re subject to Executive Order 11246, and your company had fewer female applicants than available in the general labor pool, you may need to outline how you will try to increase your pool of candidates. As a result, you’ll need to review the data each year when updating your plan. ## Ensure AAP Compliance With The Right Partner As you can see, requirements for AAPs can be complex, and compliance is essential to avoiding potential penalties. If you don’t have the expertise in-house to implement an AAP and actively manage it, you may want to seek the help of an outsourced HR provider. If you decide to go this route, [learn about Complete Payroll Solutions’ HR outsourcing solutions](https://www.completepayrollsolutions.com/hr-outsourcing) to see if we may be a good fit to help your organization maintain affirmative action plan compliance. - Share Post: - - in ![Tag Icon](https://www.completepayrollsolutions.com/hubfs/tags.png) [HR](https://www.completepayrollsolutions.com/blog/topic/hr) , [Compliance](https://www.completepayrollsolutions.com/blog/topic/compliance) [❮ Schedule H: How to Handle Wages & T...](https://www.completepayrollsolutions.com/blog/schedule-h-household-employee) [The Disadvantages Of Outsourcing HR... ❯](https://www.completepayrollsolutions.com/blog/disadvantages-of-outsourcing-hr-functions) Subscribe Enter your email address to subscribe to this blog and receive notifications of new posts by email. Categories - [Benefits](https://www.completepayrollsolutions.com/blog/topic/benefits) - [Compliance](https://www.completepayrollsolutions.com/blog/topic/compliance) - Events - General - [HR](https://www.completepayrollsolutions.com/blog/topic/hr) - Industry - News - [Payroll](https://www.completepayrollsolutions.com/blog/topic/payroll) - Press Releases - Time & Attendance ##### Related Articles & Resources ## Read Up, Learn More, Do Better [![EEO Laws - AAP](https://www.completepayrollsolutions.com/hs-fs/hubfs/EEO%20Laws-1.jpg?width=800&height=500&name=EEO%20Laws-1.jpg)](https://www.completepayrollsolutions.com/blog/eeo-laws) ###### [Blog EEO Laws: What They Are And How To Be Compliant EEO laws prohibit discrimination against a job applicant or employee based on their race, color, religion, sex, age, national origin, and physical or mental disability in all aspects of employment, including promotion, training, and other personnel actions. After reading this article, you’ll understand the requirements when it comes to EEO to ensure that your business avoids the risk of an EEO charge. [Read Full Article](https://www.completepayrollsolutions.com/blog/eeo-laws)](https://www.completepayrollsolutions.com/blog/eeo-laws) [![Pay Equity - AAP](https://www.completepayrollsolutions.com/hs-fs/hubfs/Pay%20Equity-1.jpg?width=800&height=500&name=Pay%20Equity-1.jpg)](https://www.completepayrollsolutions.com/blog/pay-equity) ###### [Blog ​​Pay Equity: An Employer’s Guide To Avoiding Wage Discrimination When it comes to paying your workforce, there’s a lot to consider. Pay equity is an increasingly important issue when setting compensation. That’s because, while the topic has been regulated on a federal level for decades, states are stepping up their attention to the matter with a number of recent laws. To help you understand what you need to do to stay compliant, we’ll break it down for you step by step. [Read Full Article](https://www.completepayrollsolutions.com/blog/pay-equity)](https://www.completepayrollsolutions.com/blog/pay-equity) [![Employee Handbooks](https://www.completepayrollsolutions.com/hs-fs/hubfs/Employee%20Handbooks.jpg?width=800&height=500&name=Employee%20Handbooks.jpg)](https://www.completepayrollsolutions.com/blog/employee-handbooks) ###### [Blog A Beginner’s Guide To Employee Handbooks (+10 Must-Haves For Yours) Whether you’re hiring employees for the first time or are growing and want to make sure your business is protected, you’re probably here because you’ve realized your business needs an employee handbook. But creating employee handbooks can be daunting. We’re going to try to make it easier for you. In this article, we’ll describe the importance of employee handbooks and the top must-haves for yours. [Read Full Article](https://www.completepayrollsolutions.com/blog/employee-handbooks)](https://www.completepayrollsolutions.com/blog/employee-handbooks) ![CPS Logo](https://www.completepayrollsolutions.com/hubfs/CPS%20Logo_rgb-2.svg "CPS Logo") Solutions - [Payroll](https://www.completepayrollsolutions.com/payroll-outsourcing) - [Talent Management](https://www.completepayrollsolutions.com/talent-management) - [Benefits](https://www.completepayrollsolutions.com/employee-benefits) - [HR Solutions](https://www.completepayrollsolutions.com/hr-outsourcing) - [Time & Attendance](https://www.completepayrollsolutions.com/time-and-attendance) - [Employee Engagement](https://www.completepayrollsolutions.com/employee-engagement) Who We Serve - [Startups](https://www.completepayrollsolutions.com/payroll-and-hr-startups) - [Small & Medium Businesses](https://www.completepayrollsolutions.com/small-medium-business-payroll-benefits) - [Large & Enterprise Businesses](https://www.completepayrollsolutions.com/payroll-and-hr-outsourcing-large-business) - [Industries](https://www.completepayrollsolutions.com/who-we-serve) - [Our Partners](https://www.completepayrollsolutions.com/partnerships) Resources - [Blog](https://www.completepayrollsolutions.com/blog) - [Learning Center](https://www.completepayrollsolutions.com/resources) - [Employee, Federal & State Forms](https://www.completepayrollsolutions.com/employee-federal-state-forms) Who We Are - [Contact](https://www.completepayrollsolutions.com/contact-us) - [About Us](https://www.completepayrollsolutions.com/about-us) - [Careers](https://www.completepayrollsolutions.com/careers/) - [Data Security & Privacy](https://www.completepayrollsolutions.com/data-security) Solutions - [Payroll](https://www.completepayrollsolutions.com/payroll-outsourcing) - [Talent Management](https://www.completepayrollsolutions.com/talent-management) - [Benefits](https://www.completepayrollsolutions.com/employee-benefits) - [HR Solutions](https://www.completepayrollsolutions.com/hr-outsourcing) - [Time & Attendance](https://www.completepayrollsolutions.com/time-and-attendance) - [Employee Engagement](https://www.completepayrollsolutions.com/employee-engagement) Resources - [Blog](https://www.completepayrollsolutions.com/blog) - [Learning Center](https://www.completepayrollsolutions.com/resources) - [Employee, Federal & State Forms](https://www.completepayrollsolutions.com/employee-federal-state-forms) - [Pricing](https://www.completepayrollsolutions.com/plans-and-pricing) Who We Serve - [Startups](https://www.completepayrollsolutions.com/payroll-and-hr-startups) - [Small & Medium Businesses](https://www.completepayrollsolutions.com/small-medium-business-payroll-benefits) - [Large & Enterprise Businesses](https://www.completepayrollsolutions.com/payroll-and-hr-outsourcing-large-business) - [Industries](https://www.completepayrollsolutions.com/who-we-serve) - [Our Partners](https://www.completepayrollsolutions.com/partnerships) Who We Are - [Contact](https://www.completepayrollsolutions.com/contact-us) - [About Us](https://www.completepayrollsolutions.com/about-us) - [Leadership](https://www.completepayrollsolutions.com/management-team) - [Careers](https://www.completepayrollsolutions.com/careers/) - [Data Security & Privacy](https://www.completepayrollsolutions.com/data-security) 100.113.58.77 https://www.completepayrollsolutions.com/blog/what-is-an-affirmative-action-plan What is an affirmative action plan? An Employer’s Guide To Compliance 2026-08-05 11:41:38 © Copyright 2024 Complete Payroll Solutions: HR, Payroll, and Benefits | [Privacy Policy](https://www.completepayrollsolutions.com/privacy-policy/) | One Carando Drive, Springfield, MA 01104 ```json { "@context" : "https://schema.org", "@type" : "BlogPosting", "author" : { "@type" : "Person", "name" : "Karyn H. Rhodes | SHRM-SCP, SPHR", "url" : "https://www.completepayrollsolutions.com/blog/author/karyn-h-rhodes-shrm-scp-sphr" }, "dateModified" : "2023-07-27T13:26:32.661Z", "datePublished" : "2023-07-27T13:26:32.000Z", "headline" : "What is an affirmative action plan? An Employer’s Guide To Compliance", "image" : [ "https://www.completepayrollsolutions.com/hubfs/Affirmative%20Action%20Plan.jpg" ], "mainEntityOfPage" : { "@id" : "https://www.completepayrollsolutions.com/blog/what-is-an-affirmative-action-plan", "@type" : "WebPage" }, "publisher" : { "@type" : "Organization", "logo" : { "@type" : "ImageObject", "url" : "https://www.completepayrollsolutions.com/hubfs/CPS%20Logo_rgb.png" }, "name" : "Complete Payroll Solutions" } } ```