The obligations under E.O. 11246, VEVRAA, and Section 503 apply equally to all federal contractors and subcontractors, unless exempted under 41 C.F.R. §60-1.5. However, they may be other requirements that companies have to comply with if they are in the Small Business Administration’s 8(a) program. I am not aware of separate affirmative action or equal opportunity obligations on top of what the federal regulations require, but the SBA does have certain requirements for eligibility into the program, which the SBA evaluates annually in order to continue to participate in the 8(a) program. One of these requirements is that the business is 51 percent owned and controlled by U.S. citizens who are economically and socially disadvantaged. For guidance, please check out the SBA website’s page on the 8(a) Program and the Annual Update requirement. You can also contact your local SBA District Office for assistance. OFCCP also has a Guide for Small Businesses with Federal Contracts that you might find helpful.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.