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It doesn't matter when the requisition was opened. All of the applicants are counted in the AAP year when the requisition is filled. For instance, you have a calendar plan year and the requisition was opened on 12/1/15 but not filled until 1/15/16, all the applicants (and hire) would not be considered in the 2016 plan data because they were hired outside of the date perimeters for the collection of the personnel activity data to support the 2016 plan (1/1/15 - 12/31/15). However, if the requisition was filled on 12/30/15, all of the applicants (and hire) would be counted in the data. If you have one requisition with two hires and they crossed over plan years then you do need to count some of the applicant in the 2016 and some in the 2017 data. For example, requisition was opened 12/1/15 and first hire was made 12/30/15. I would count only those applicants in the requisition who applied and were considered for this initial hire. Anyone that applied to the same requisition after the date of the offer should not be considered in the 2016 AAP data. Those applicants would be counted in the 2017 data to support the hire made in 2016. Needless to say, if you know that one requisition is going to cross over plan years, it is best to close it out and re-open another one. You can transfer over the applicants after the position was filled the first time since you know that they have shown an expression of interest in the same position.
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.