A company may hire more than one individual from a requisition. Four new requisitions need not be created for OFCCP compliance. It is a good thing to establish what will happen up front as you have done. The appropriate analyses are to compare those that competed for a position (depending on how the company does its hiring) against each other. Therefore, since there were five hires from the pool, those applicants should be used in any comparative analyses versus conducting analyses by requisition. There is nothing inherently wrong or dangerous of the practice outlined above, but it may impact how the analyses should be done (by applicant pool versus using a requisition system). Make sure to run your annual analyses using the method that captures the appropriate pool (i.e., analyses by requisition or using a combined pool). If you have very large numbers (a high turnover in jobs for example), a statistical result sometimes appears simply because of the large numbers. Foregoing a proper requisition practice could require the company to analyze a larger pool.

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.