The guidance from OFCCP specifies a single contract of $50,000 or more as the threshold for developing a written Affirmative Action Program to comply with E.O. 11246: “If a company has at least 50 employees and a single contract of $50,000 or more, then it must also develop an Affirmative Action Program (AAP), as described at 41 CFR 60–2. Companies whose sole coverage comes from construction contracts or federally assisted construction contracts are not required to develop an AAP, but they must comply with 16 specific affirmative actions outlined in the equal opportunity construction contract clause.” The same is true for Section 503 and VEVRAA compliance, except the contract threshold is higher for VEVRAA. Section 503: “If the company has at least 50 employees and a single contract of $50,000 or more, then it must also develop a Section 503 AAP, as described in 41 CFR 60–741, Subpart C. Section 503 applies to businesses with federal construction contracts, but not to businesses with federally assisted construction contracts.” VEVRAA: “If the company has at least 50 employees and a single contract of $150,000 or more, then it must also develop a VEVRAA AAP, as described in 41 CFR 60–300, Subpart C. VEVRAA applies to businesses with federal construction contracts, but not to businesses with federally assisted construction contracts.” Note, however, that this is not the threshold that determines if a company is a federal contractor. This is just the threshold that will require a federal contractor to develop a written AAP. You are still a covered contractor subject to the nondiscrimination and affirmative action requirements enforced by OFCCP if you fall under the following: • E.O. 11246: Any number of employees and federal contracts (including federally assisted construction contracts) totaling more than $10,000 • Section 503: Any number of employees and a federal contract of more than $15,000 • VEVRAA: Any number of employees and a federal contract of $150,000 or more For more information, refer to OFCCP’s Infographic and their webpage on Jurisdictional Thresholds.

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.