Like our site's new design? In April 2023, Circa was acquired by Mitratech.
>> Learn More

OFCCP Certification 2023 – Plan Start Date

Anonymous - September 5, 2023
Back to Ask the Experts

I noticed on the Certification page they ask for the start date of the AAP you are certifying. I am confused about what that means exactly and I find the FAQ on that to also be confusing. See FAQ below. Can you please explain?

16. For covered government contractors with a June 1 plan start date, will OFCCP require the 2022 or 2023 AAP to be certified?
Covered federal contractors and subcontractors are required to use the OFCCP Contractor Portal to certify whether they are currently meeting their requirement to develop and maintain annual AAPs. When a contractor selects a response to the certification statement through OFCCP’s Contractor Portal, it is selecting the response that reflects its AAP status as of the date it certifies. For example, if a contractor with a June 1, 2023 AAP start date certifies when the Contractor Portal opens for certification on March 31, 2023, then the contractor would be certifying the 2022 AAP (effective June 1, 2022 through May 31, 2023). If the contractor certifies on or after June 1, 2023, it would be certifying the 2023 AAP (effective June 1, 2023 through May 31, 2024).

1 Answer

Our Experts

Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.

Ahmed Younies

President and CEO, HR Unlimited, Inc.

Alissa Horvitz, Esq.

Member Attorney, Roffman Horvitz, PLC

Allen Hudson, PHR, SHRM-CP

CEO, HudsonMann

Angel Fischer

Angel Fischer

Bill Osterndorf

Principal Consultant, DCI Consulting Group, Inc

Carla Irwin, Esq.

President, Carla Irwin & Associates, Inc.

Craig Leen

Board Member, Circa

David Cohen

President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Julia Mendez Achee

Senior Consultant - EEO/Affirmative Action Division, Biddle Consulting Group

Lisa Kaiser, Esq.

Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

Roselle Rogers

Vice President, Diversity, Equity, and Inclusion, Circa

Stephanie Stahr

Senior HR Consultant, Berkshire Associates

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

Skip to content