The regulations require "employment openings" to be listed with the state employment service. It sounds like, from your description above, that your company is not advertising actual openings, but is advertising potential openings, so it does not appear as if the listing requirement is yet triggered. However, if the company were to collect applications to consider for positions if the bid was won later, then I would recommend the company list the jobs at the bid phase consistent with the regulations, so that the company is not inadvertently circumventing the rules.
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.
