In checking with OFCCP, there doesn’t seem to be a prescribed method to handle this. Treating them as hires, transfers, or simply listing them, are all acceptable. The important thing is that the contractor should be able to explain the data and what happened. Each method presents its own challenges as you already stated. You are correct that simply listing them would not align with the employees from your previous plan year, but that is explainable. Treating them as hires will have its own challenges as you may end up mixing two different applicant pools. For example, if your sales team from the other company is comprised of 9 males and 1 female, and in addition to acquiring all 10 employees, you also hired 1 male and 1 female from an applicant pool of 20 males and 20 females. You have actually selected at an equal rate; but it will look like your selection rate is 50% for males (10 hires from 20 applicants) and 10% for females (2 hires from 20 applicants). So you will need to refine your data to identify distinct groups in your applicant pool, and explain what happened. OFCCP might also look into the employees you retained from the acquired company and how you selected which employees to retain. So make sure that you keep records documenting your selection process.