The recordkeeping obligations with respect to applicants are set forth in Executive Order 11246. This Executive Order applies to businesses with federal contracts and federally-assisted construction contracts totaling more than $10,000. Note that the $10,000 threshold is a cumulative number for all contracts held and applies regardless of the company size. OFCCP has also developed a couple of resources that I find extremely useful in understanding the basic recordkeeping requirements for federal contractors. I would encourage you to check out the Small Federal Contractor Technical Assistance Guide. There is a really good list of records contractors must maintain in Appendix F on pages 36 to 38 of that guide. In addition, I would also recommend taking a look at OFCCP’s Applicant Tracking Guide which lays out in an infographic format federal contractors’ Internet Applicant and traditional applicant recordkeeping requirements.
