On March 31, 2022, the OFCCP opened the AAP Certification requirement through their new Contractor Portal. The same day, the agency hosted a webinar demonstrating how to navigate the Contractor Portal and how to complete the AAP Certification process. The OFCCP issued an email immediately after opening the AAP Certification, directing federal government contractors to complete their company’s AAP Certification by June 30, 2022.
Many AAP compliance professionals have been speculating how contractors must “certify, on an annual basis, whether they have developed and maintained an AAP for each establishment” because details of the process were not being disclosed. During the webinar, the agency revealed that the process requires contractors to declare whether or not they have developed and maintained affirmative action programs at each establishment according to 41 CFR Chapter 60 and to checkmark a box attesting that this AAP certification is true. Contractors can select which establishments to certify, and can certify different establishments at different times, as long as it is within the March 31 – June 30, 2022 timeframe. At this point, there are no other requirements to certify beyond the certification question, the declaration statement, and ensuring each establishment’s information is updated and correct. The information includes things such as Establishment EEO-1 Number, Name, DUNS, NAICS, EIN, Employee Headcount, Address, and Point of Contact information.
For more information, please see the OFCCP’s Frequently Asked Questions and Contractor Portal User Guide. If you have not already done so, please let your Maly consultant know whether or not you would like for us to register and certify AAP compliance on behalf of your company.
