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Federal Contractors and their Applicable Subcontractors - Your OFCCP Registration/Certification Deadline for 2023 AAPs is Now Here!

For federal government contractors and their applicable subcontractors, your OFCCP Portal registration/certification deadline is now here for 2023 affirmative action plans (AAPs) – it is Thursday, June 29, 2023! The OFCCP has not extended this deadline as of yet and has indicated that, unlike last year, it most likely will not do so this year – so be alert. Previous updates on OFCCP compliance: January 26, 2023; June 24, 2022; January 28, 2022

Regarding the submission of the EEO-1 Report, an annual obligation of federal contractors and their applicable subcontractors, the EEOC has announced that reporting for the 2022 year is scheduled to begin in mid-July 2023 through the EEOC’s Portal. As of yet, no reporting deadline has been set for the 2022 EEO-1. It has been assumed that the data for the EEO-1 Report is to be from a pay period in the fourth calendar quarter of 2022, and it has been speculated that the EEOC might return to the traditional September 30 reporting deadline from years past, which is the current deadline for the VETS-4212 Report for 2022. But again, as of yet no word from the EEOC on a deadline.

Of note with respect to the June 29, 2023, OFCCP Portal registration/certification deadline is that a federal contractor or an applicable subcontractor who has never been issued an EEO-1 Report identifier is not able to register/certify in the OFCCP Portal until it is required to file an EEO-1 Report. Such a federal contractor or subcontractor that is unable to obtain an EEO-1 identifier to file an EEO-1 Report until a date beyond this OFCCP deadline is still nonetheless required to meet its obligations to develop and maintain the requisite annual AAPs for 2023; thus, out of an abundance of caution those AAPs should be completed and in place by the OFCCP DEADLINE and a record of such completion should be documented and maintained.

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  • Jack D. Rowe
    Senior Counsel

    Jack Rowe concentrates on employment and labor relations issues. He represents management and the business sector in equal employment opportunity, personnel relations and traditional labor matters, including federal, state ...

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