It is OK for a federal contractor to promote internal candidates without posting a position internally. This would be considered a noncompetitive promotion. The annual analysis of promotions will provide insights as to whether the noncompetitive promotions are resulting in adverse impact against a protected group.
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.