The Hires, Applicants, Promotions, and Terminations should be dated beginning (and including) the full year. In your case January 1, 2017 through December 31, 2017. The employee snapshot should be dated December 31, 2017. Best practice in this case is to prepare the plan as soon as reasonably possible after the first of the year. The regulations state that the AAPs must be updated annually. If audited, the company will be required to submit the plan and accompanying data within 30 days, so the plan should be in place before thirty days, of course.

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.