The primary issue here isn't whether you need a formal requisition or whether you need to follow your standard recruitment and selection practices. The primary issue here is that federal contractors and subcontractors are required to list open positions with the relevant Employment Service Delivery System (ESDS) office (i.e. the relevant state employment service office) under the affirmative action regulations for protected veterans. These regulations provide for only three exceptions in regard to positions which do not need to be listed with an ESDS office: - Openings of three days or less - Openings that will be filled internally - Openings that involve "executive and senior management" positions as defined in the regulations See 41 CFR 60-300.5(a) This means that if you are filling a professional position that requires a high level of skill or experience, it still needs to be listed with an ESDS office. The only way to effectively do a blind posting without involving your organization would be to have a staffing agency list the position with an ESDS office under the staffing agency's name, and then provide you with candidates. You would need to insist that the staffing agency provide you with copy of the ESDS listing in case it is requested during an OFCCP compliance review. If you intend to do a blind posting on your own to various job boards, you will likely run into trouble with the ESDS listing requirement. You can certainly talk to a local veteran's rep at one of the ESDS offices to see how this situation might be handled so long as you know ahead of time that you aren't likely to be able to use an ESDS office to run a blind ad. A secondary issue that you face is that federal contractors and subcontractors are required to make outreach efforts to recruit qualified minorities, females, veterans, and individuals with disabilities. You may find job boards or other recruitment sources that serve these groups that are willing to take your blind ad. However, the fact that you're running a blind posting does not relieve your organization of its outreach responsibilities. A final note on process. As I said above, you can decide that in certain special circumstances, you will follow a different recruitment and selection process than your usual process. However, you will need to ensure that this process allows you to appropriately collect data, including demographic data on race, gender, veteran, and disability status, from qualified applicants. You will also need to ensure that the process gives appropriate treatment to all candidates during the selection process. Here's the bottom line: it's hard to do a blind posting and remain compliant with the federal affirmative action regulations.
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.