Here is the OFCCP's answer to the FAQ on employment agencies/search firms: If a covered employer contracts with an employment agency to screen and refer job seekers using the employer’s selection procedures, what records must be maintained? The contractor’s recordkeeping obligations are the same whether it screens job seekers itself or whether it contracts with an employment agency to screen job seekers on its behalf with the employer’s selection procedures. If an employer contracts with an employment agency to screen job seekers on its behalf, it would be prudent to address expressly in its contract with the employment agency the records the agency will be expected to maintain regarding searches made on the employer’s behalf. The Executive Order recordkeeping obligation belongs to the Federal contractor, not the retained employment agency, and it is the contactor’s responsibility to ensure that the agency keeps for it whatever records the contractor will be expected to have. With regard to listing your jobs with ESDS, you only need to do it once. So either you or the agency on behalf of your company need to list with ESDS,

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.