Affirmative Action Plan (AAP)

What Is an Affirmative Action Plan (AAP)?

An affirmative action plan (AAP) is a plan or program that outlines a federal contractor or subcontractor’s efforts to provide equal employment opportunities and generally support the advancement of employees regardless of gender, race, disability, or veteran status. Federal guidelines recommend reviewing and updating AAPs at least once a year.

To see sample AAPs and read the federal regulations governing them, visit this Office of Federal Contracts Compliance Programs (OFCCP) website.

Who Is Required to Have an Affirmative Action Plan?

As previously mentioned, formal affirmative action plans are only required for federal contractors and subcontractors. There are additional conditions set forth by the OFCCP, which oversees federal contractor compliance. Their conditions include all non-construction federal contractors or subcontractor who: 

• Have 50 or more employees

• Are within 120 days from the start of the federal contract

• Have a federal contract or subcontract of at least 50,000 dollars

• Have government bills of lading totalling at least 50,000 dollars in any 12-month period

• Serve as a depository of federal funds in any amount

• Or are a financial institution that is an issuing and paying agent for U.S. savings bonds and savings notes

Be sure to check with the OFCCP if you think you meet these conditions.

How Should an Organization Prepare an Affirmative Action Plan?

According to the OFCCP, contractors should employ internal audits and reporting systems to keep track of relevant employee demographic information, monitor anti-discrimination initiatives, and analyze the effectiveness of any Affirmative Action Plan. This should include information on: 

• Applicant and employee demographics collected voluntarily during the hiring process with an applicant flow log

• Promotions

• Transfers

• Terminations

• Compensation

To be clear, an AAP is the written document of the plan and policies that will guide the company forward over the next year, not the audit or reporting system that the company uses. However, it relies on the results and data collected from both.