This question has many layers. You, as the contractor, are responsible for the actions of the outside recruiters. The outside recruiters, standing in for you -- the federal contractor -- are responsible for obtaining demographic (race, gender, disability status and veteran status) for all candidates that they believe meet the minimum qualifications. A best practice is to have the recruiters ask all interested applicants to apply to the ATS, as OFCCP may ultimately have a different determination regarding minimum qualifications.