Last Updated on April 7, 2026 by MyHRConcierge

Affirmative Action Plan (AAP) compliance is a large responsibility for many employers, particularly federal contractors and subcontractors. While it is often viewed strictly through a regulatory lens, AAP compliance also reflects an organization’s broader commitment to equal employment opportunity and fair workplace practices. 

As it stands in 2026, some long-standing requirements have been modified. However, AAP compliance has not been eliminated entirely. Instead, it has shifted in scope, requiring employers to take a more targeted and informed approach. Understanding what still applies- and what no longer does- is essential for maintaining compliance and avoiding unnecessary risk.

What Is an Affirmative Action Plan (AAP)?

An Affirmative Action Plan (AAP) is a formal, written program that outlines an employer’s efforts to ensure equal employment opportunities for all individuals, regardless of race, gender, disability or veteran status. These plans are required for certain employers doing business with the federal government and are enforced by the Office of Federal Contract Compliance Programs (OFCCP). At its core, an AAP requires employers to take a close look at their workforce and hiring practices. 

Historically, AAPs required federal contractors to analyze workforce demographics and set goals related to the representation of women and minorities. Today, AAPs primarily focus on compliance obligations related to individuals with disabilities and protected veterans, while broader anti-discrimination requirements still apply to all employers under existing federal laws.

What Changed in 2025?

Affirmative action requirements for federal contractors continue to evolve, and employers should monitor regulatory updates closely. In 2025,  Executive Order 11246– which prohibited employment discrimination based on race and sex- was not made mandatory. As a result, federal contractors were given a cease and desist in regards to AAPs addressing race or gender representation, and enforcement of those requirements has ceased. They were given a 90-day wind-down period, ending on April 21, 2025.

This marks a significant shift from prior years, where employers were expected to conduct detailed workforce analyses and establish placement goals tied to diversity metrics. However, it is important to note that this change did not eliminate all affirmative action obligations.

Who Must Comply with AAP Requirements Today?

AAP requirements now apply more narrowly and primarily impact federal contractors and subcontractors that meet certain employee and contract thresholds. In general, employers with 50 or more employees and qualifying federal contracts are required to maintain affirmative action programs under applicable laws.

Today, these obligations stem from two primary regulations. Under Section 503 of the Rehabilitation Act, covered employers must maintain an affirmative action program for individuals with disabilities, including workforce analysis, outreach efforts, and utilization tracking. Similarly, under Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), employers must maintain a program for protected veterans, including establishing annual hiring benchmarks and documenting recruitment efforts.

These requirements apply to both prime contractors and subcontractors, meaning organizations may be covered even if they do not contract directly with the federal government. Additionally, the employee threshold applies across the entire organization, not just those supporting federal contract work. Because contract thresholds and regulatory requirements may be adjusted over time, employers should regularly review their status to ensure continued compliance.

Understanding the Core Elements of Compliance

AAP compliance begins with a detailed analysis of the workforce. Employers must group jobs into categories and evaluate representation within each group. This process helps identify whether certain groups are underrepresented when compared to the available talent pool in the relevant labor market.

When underrepresentation is found, employers are expected to establish placement goals. It is important to understand that these goals are not quotas or mandates. Rather, they serve as benchmarks to guide good-faith efforts in recruitment, hiring and advancement.

Equally important are the action-oriented programs that support these goals. These may involve refining recruiting strategies, expanding outreach efforts or reviewing internal policies to ensure fairness in promotions and compensation. Over time, employers must also evaluate whether these efforts are effective and make adjustments as needed.

Practical Tips for Maintaining Compliance

AAP compliance begins with a detailed analysis of the workforce. Employers must group jobs into categories and evaluate representation within each group. This process helps identify whether certain groups are underrepresented when compared to the available talent pool in the relevant labor market.

When underrepresentation is found, employers are expected to establish placement goals. It is important to understand that these goals are not quotas or mandates. Rather, they serve as benchmarks to guide good-faith efforts in recruitment, hiring and advancement.

Equally important are the action-oriented programs that support these goals. These may involve refining recruiting strategies, expanding outreach efforts or reviewing internal policies to ensure fairness in promotions and compensation. Over time, employers must also evaluate whether these efforts are effective and make adjustments as needed.

Looking Ahead: AAP Compliance and Organizational Success

AAP compliance in 2026 looks very different than it did just a year ago. While some requirements have been changed, obligations tied to individuals with disabilities and protected veterans remain firmly in place. Employers who take the time to understand these changes and adjust their approach accordingly will be better equipped to stay compliant and confident in an evolving regulatory landscape.

For more information on how to enhance your organization’s compliance efforts, contact MyHRConcierge at 855-538-6947 ext.108, ccooley@myhrconcierge.com. Or, schedule a convenient consultation below: