This is not one of those situations where OFCCP has provided a straightforward answer, and thus we need to consider how the agency might approach this question. If you have a candidate who started the application process, but failed to complete the application process, there appears to have been an initial expression of interest. The candidate could then be considered a withdrawal (which would mean the candidate is not an "applicant" as defined by OFCCP) or the candidate could be considered to have failed to follow a company protocol to receive consideration (which again would mean the candidate is not an "applicant"). However, one could certainly argue that the candidate never even made an expression of interest, since the candidate never fully completed going through the application process. In this case, the candidate might fall into the unusual category of being someone who appears in an applicant tracking system, and yet doesn't even rise to the level of being a candidate where there are record retention requirements. Since OFCCP generally has no reporting requirements regarding persons who express interest but who are not "applicants" (as defined by the agency), it probably doesn't entirely matter how you conceptualize such candidates. The only time OFCCP might ask for information on persons who expressed interest and who are not "applicants" is the situation where the agency believes that a company has misapplied the "Internet applicant" rule. Even in this situation, someone who never finishes the application process is unlikely to be looked at as an applicant. That person simply isn't a viable candidate. It's not clear why a company would be counting expressions of interest rather than counting "applicants," at least in the OFCCP context. However, if you are counting expressions of interest for some purpose, then you will need to make a strategic decision as to what to do with someone who fails to complete the application process. Please note that there are actually a number of subtle issues associated with your question that I don't have space to address here. For example, if an individual with a disability is having problems using your online application system to express interest, that person may ultimately be considered not just a person who express interest but an "applicant" by OFCCP. Thus, please realize that the general ideas I've discussed above may not be entirely applicable in every instance to specific circumstances your company encounters.

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.