The Office of Federal Contract Compliance Programs (OFCCP) recently posted sample affirmative action plans (AAPs) for individuals with disabilities and veterans to its website, available here.

The forms should be helpful guidance for companies who are federal contractors and subcontractors who are looking to comply with new regulations that took effect on March 24, 2014 but are only now being integrated into AAPs that were already in existence on the regulations’ effective date. Many contractors and subcontractors are incorporating or incorporated these regulatory changes into their annual AAPs in 2015 for the first time.

The samples are designed to be used by contractors with less than 150 employees because the sample AAPs utilize EEO-1 categories for job groups. In reviewing the samples, it is easy to see how OFCCP expects that affirmative action plans should look for larger contractors under the new regulations. Obviously, there is no one right way to prepare an affirmative action plan—which OFCCP recognizes. And both OFCCP and we agree that AAPs should be customized to reflect organizational structure, policies, practices, programs, and data. The AAP process should not be a fill-in-the-blank exercise.

The samples posted are “transition year” AAPs. Because the new regulations require analysis of hiring and applicant data on individuals with disabilities and veterans for the past 3 years, the first 3 years of AAPs implementing the new regulations will involve incomplete data because contractors were under no obligation to have collected this data prior to March 24, 2014. The samples reflect that reality. OFCCP promises updated samples will be posted showing how contractors should utilize and analyze a full four years of hiring and applicant data.

On the same webpage, OFCCP also maintains a sample AAP for Executive Order 11246 that was first posted in 2004.