Hi Colin, A formal application process is not required by the rules that OFCCP enforces, but only that the expression of interest be considered. Once a company is reviewing resumes, if the other two Internet applicant requirements are met, then the individual is an applicant according to OFCCP and the pool may extend to those that use "Easy Apply." Some companies will automatically require the "Easy Apply" candidates to fill in a company application before being considered and then only candidates who fill in the application move to the next step in the process. I hope this answers your question. This is a difficult situation for many contractors.

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.