An affirmative action plan (AAP) is a written program that explains how an organization will meet applicable equal employment opportunity obligations. In the United States, the term often refers to plans that certain federal contractors must maintain under Section 503 of the Rehabilitation Act or the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). Section 503 concerns employment opportunities for qualified individuals with disabilities, while VEVRAA concerns protected veterans. An AAP assigns responsibility for the program and describes how the organization will review employment practices and assess outreach and recruitment. The requirements depend on the applicable law and the organization’s contract, so there is no single template for every employer. An AAP is not permission to make employment decisions based on protected characteristics or to guarantee jobs to particular groups. Its purpose is to support equal opportunity through lawful processes and ongoing review.
Table of Contents
- Which Federal Contractors Need a Written Aap?
- How Have Federal Aap Requirements Changed?
- What Does a Federal Contractor Aap Contain?
- How Is an Aap Different from a Quota or Diversity Initiative?
- How Should Employers Maintain and Review an Aap?
- How Does an Aap Relate to Contingent Workers?
Which Federal Contractors Need a Written Aap?
Coverage depends on the statute, contract value, and workforce size. Under current federal thresholds, a contractor generally must maintain a written Section 503 AAP when it has at least 50 employees and a federal contract or subcontract of $50,000 or more. A written VEVRAA AAP generally applies when a contractor has at least 50 employees and a covered federal contract or subcontract of $200,000 or more. The U.S. Department of Labor’s summary of federal contractor thresholds explains these requirements.
The written-plan thresholds are not the same as basic statutory coverage. Section 503 nondiscrimination and related requirements generally apply to contracts exceeding $20,000 even if a contractor does not meet the written AAP threshold. VEVRAA’s basic contract threshold is $200,000. A contractor below a written-plan threshold may still have duties under the relevant law. Contract terms and applicable exemptions can affect the analysis, so contractors should confirm the requirements that apply to their circumstances.
State and local rules may impose separate requirements. Employers should identify the governing authority and applicable contract terms before relying on a plan template. A federal contractor may need to consider both Section 503 and VEVRAA, with a separate program for each applicable statute. The duties under one law should not be assumed to satisfy the requirements of another. An organization should also distinguish having a written plan from meeting its broader nondiscrimination and recordkeeping responsibilities.
How Have Federal Aap Requirements Changed?
Federal contractors may encounter older plans that were prepared under Executive Order 11246. Executive Order 14173 revoked that order on January 21, 2025. The Department of Labor has stated that it ceased enforcing the former order’s requirements while continuing its work under Section 503 and VEVRAA. Those statutes remain important sources of federal contractor AAP duties. Older materials about race- and sex-based plan requirements should not be assumed to describe the current federal requirements.
Contractors should review the date and legal basis of any plan template they use. A document written for an earlier rule may refer to goals or procedures that no longer apply, while omitting requirements that remain in effect. Section 503 and VEVRAA continue to have their own coverage rules and program obligations. Employers should check current official guidance before revising a plan or deciding what employment information to collect. This is particularly important when a contractor has relied on a previous plan for several years.
VEVRAA requires covered contractors with written plans to set an annual hiring benchmark for protected veterans. A contractor may use the national percentage published by OFCCP or an individualized method allowed by regulation. The benchmark helps assess recruitment and hiring efforts; it is not a fixed hiring quota. For updates to current rules and guidance, contractors can consult OFCCP’s official materials and determine whether an existing plan needs revision. Legal advice may be appropriate when coverage or the effect of a regulatory change is uncertain.
What Does a Federal Contractor Aap Contain?
An AAP is an operating document rather than only a statement of support for equal opportunity. Depending on the statute, it describes the contractor’s policy and assigns responsibility for carrying it out. It explains how the contractor reviews personnel processes and considers whether job qualifications are applied appropriately. It may also describe how the organization communicates its policy and provides relevant training. The plan should connect these commitments to actual recruiting and employment practices so that responsible staff can put them into effect.
Outreach is another practical element. A contractor documents recruitment efforts and assesses whether they help reach qualified candidates. For example, it might review whether its online application process is accessible to applicants with disabilities. If it finds a barrier, it can identify a corrective step and later assess whether that step improved access. The purpose is to examine and improve the process while retaining lawful, job-related selection standards. A plan is more useful when it identifies who will act and how the organization will follow up.
VEVRAA plans include a protected-veteran hiring benchmark and a review of outreach effectiveness. OFCCP explains that the benchmark measures progress in recruiting and hiring qualified protected veterans. It does not require a contractor to hire a predetermined number of people regardless of their qualifications. The OFCCP benchmark guidance describes the available methods. Contractors should ensure that their plan reflects the requirements of the particular statute rather than treating every AAP as identical.
How Is an Aap Different from a Quota or Diversity Initiative?
A benchmark or other numerical measure can help an employer assess whether its outreach is reaching qualified candidates. It does not by itself require a particular hiring result. Under VEVRAA, a contractor compares hiring outcomes with its benchmark and uses the comparison to evaluate recruitment efforts. A shortfall can prompt a review of the program and consideration of changes to outreach or procedures. It does not automatically establish a violation or justify treating candidates differently because of protected status.
An AAP is also distinct from a general affirmative action policy or a diversity hiring initiative. The label alone does not establish which legal requirements apply. Employers should identify the specific authority behind a plan and ensure that selection decisions use lawful criteria related to the position. They should not interpret an AAP as authority to exclude or favor applicants on an unlawful basis. Understanding the plan’s purpose and its legal foundation helps prevent confusion between compliance review and a promised hiring outcome.
How Should Employers Maintain and Review an Aap?
Covered contractors should treat the plan as a recurring management responsibility. They should identify who is responsible for each action and review whether the stated practices are being carried out. For VEVRAA, a contractor updates its written program annually and sets or adopts the applicable benchmark. It also evaluates outreach effectiveness and maintains records required by the governing rules. A current plan should describe processes that staff can follow rather than simply repeat general policy language.
A useful review looks beyond whether a document was refreshed. If an outreach channel produces few qualified applicants, the employer can examine how vacancies are shared and whether another approach may be more effective. Changes to recruiting systems or organizational responsibilities may also require updates to plan procedures. Employers should use and retain information only as permitted and needed under applicable requirements. Disability and veteran rules are not interchangeable, so a single data process may not work for both. A documented review can help show what the employer examined and what steps it took in response.
Review should involve the people who manage recruiting and employment processes. They can identify whether the written procedures reflect actual practice and whether staff understand their responsibilities. When a concern appears, the organization can determine whether it results from a process barrier or from incomplete records before choosing a response. This approach supports practical improvements without treating a numerical measure as an automatic hiring directive.
How Does an Aap Relate to Contingent Workers?
Organizations using a contingent workforce should distinguish AAP coverage from the separate question of who is responsible for employment decisions and records. A worker’s placement through a staffing firm does not by itself determine whether the worker is counted in a particular contractor’s AAP data. The applicable rules and facts about the work relationship matter. The EEOC explains that a staffing firm and its client may each be an employer of a worker, depending on the circumstances. Its guidance on contingent workers and equal employment laws discusses that distinction.
In practice, the contractor and its staffing partner should establish how they will coordinate relevant recruiting information, recordkeeping, and accommodation requests. They should keep administrative responsibilities separate from legal conclusions about coverage. A contract may assign a party to handle payroll or transmit applicant data, but that arrangement alone does not settle whether a party has statutory duties. Clear procedures can help ensure that information needed for a lawful review reaches the responsible people.
For organizations coordinating contingent workforce programs through TCWGlobal, the practical connection is the administration of recruiting and workforce information. Parties can clarify who handles each operational task and how the process supports the contractor’s own review of applicable AAP obligations. A staffing partner should receive lawful, job-related selection criteria rather than instructions to select or reject workers based on protected status. These operational arrangements support coordination, but they do not replace each party’s assessment of its legal duties.
