That is a tough question and not one directly answered by OFCCP. Since there is the potential of winning the award and therefore, hiring the qualified applicants, it is always best to do outreach and list the pipeline openings with the ESDS. If you don't do it when you post the position on your career site, it will have to be done after the fact which will not help you identify diverse candidates or show your good faith efforts to do so.
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.