The OFCCP has been approved to create an online portal for a secure method for contractors to upload AAPs electronically during audits. This new platform will become the only way for contractors to submit AAPs and materials to their compliance officer during compliance reviews. The interface will also allow all contractors to certify that they are in compliance with the OFCCP’s AAP requirements, though it is unclear if that will entail simply confirming that their organization is in compliance or if contractors will be required to annually upload their AAP documents regardless of whether or not they have been scheduled for an audit. Most speculate that the roll out of the AAP-VI website will be slow and the OFCCP will be required to clarify the authority that allows them to require annual submissions of the AAPs for all contractors.
