Here's the relevant language from the federal regulations: 41 CFR 60-300.5(a) 2. The contractor agrees to immediately list all employment openings which exist at the time of the execution of this contract and those which occur during the performance of this contract...with the appropriate employment service delivery system where the opening occurs....In order to satisfy the listing requirement described herein, contractors must provide information about the job vacancy in any manner and format permitted by the appropriate employment service delivery system which will allow that system to provide priority referral of veterans protected by VEVRAA for that job vacancy. 3. Listing of employment openings with the appropriate employment service delivery system pursuant to this clause shall be made at least concurrently with the use of any other recruitment source or effort and shall involve the normal obligations which attach to the placing of a bona fide job order... Here's your problem: this language is unhelpful to your situation. It doesn't tell us whether you need to list one job per job title, nor does it tell us what to do when the states refuse your job posting. It doesn't tell us whether you can list with one state when work may occur in multiple states. And it doesn't tell us what the rules are when an organization is creating a pipeline for future openings rather than recruiting candidates for current openings. One important part of the language is that "contractors must provide information about the job vacancy in any manner and format permitted" by the ESDS in order to allow the "priority referral of veterans". The second part of this sentence is absolutely critical. The job listing requirement in the regulations is a mechanism to ensure there is priority referral of veterans. Thus, whatever is done to ensure that priority referral occurs is going to help meet the requirements in the veterans regulations. The first part of that language about providing information in any manner and format permitted by the ESDS has become a problem for many federal contractors and subcontractors. The issue you have run into with the states requiring a physical presence in the state is a common one. OFCCP seems to have recognized this, and when this situation occurs, OFCCP allows organizations to list positions in the state where they have their headquarters, or in a nearby state where they have significant operations, or in a state where the HR representatives involved in recruiting and selection are based. There is no specific written guidance OFCCP has provided in this regard, and thus any particular compliance officer may have his or her own ideas about this. However, OFCCP generally will give organizations some leeway if an effort is made to meet the veteran preference requirement. The language about "manner and format" is also a problem in regard to your question about posting one job per state where you will be hiring multiple candidates. OFCCP seems to allow organizations to hire multiple candidates from one applicant pool so long as all hires are for the same job title and that the qualifications for that one job title are applied uniformly. (Thus, OFCCP would not be troubled if you hired 30 assemblers from one pool, so long as the job qualifications were always the same. Conversely, OFCCP would likely ask many questions if you hired 30 assemblers, 15 welders, 10 grinders, and 10 mechanics from the same applicant pool.) Whether a particular state would allow you to indicate you are hiring multiple persons into one job and that these persons may be working in a variety of locations is something that is up to the state. The relevant ESDS will determine the manner and format of job listings, including whether listings must be for single positions or whether they can be for multiple openings in multiple locations. All of this means there is not a simple answer here. The starting point is this: -Work closely with the ESDS office where your headquarters is, and/or work closely with the ESDS offices where your HR staff involved in the recruitment process are based. -Avoid job postings for generic openings (i.e. "production" or "general" or "factor" or "construction"). -Ensure that job postings with the ESDS are made at least contemporaneously with any other type of advertising. -Finally, whatever you do, make a commitment to ensuring that the veteran preference through the ESDS is somehow carried out.

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.