From a purely mandatory job listing compliance standpoint, there is no need to list the job with the ESDS now and this is not an issue as long as the job is listed with the ESDS and outreach is undertaken once the actual vacancy occurs. That being said, there are other considerations as far as how this practice expands your applicant pool, what constitutes an Internet applicant and an expression of interest, the recordkeeping requirements for internal resume database searches, among others, that you probably would want to discuss with your AAP counsel. I also encourage you to look up similar questions on pooling or "pipelining" candidates that have been answered on this forum before by several experts.

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.