OFCCP Announces Changes to Functional Affirmative Action Plans


Federal Contractors


September 21, 2022



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The Office of Federal Contract Compliance Programs (OFCCP) recently announced changes to functional Affirmative Action Plans (FAAP). The FAAP program allows federal contractors to create an affirmative action program based on business units, instead of having the program apply to the entire business. Key changes to Directive 2013-1 (Revision 3) are as follows:

  • Federal contractors with approved FAAPs must notify OFCCP within 60 calendar days of any changes to their primary corporate contact listed in the FAAP agreement.
  • Federal contractors with approved FAAPs must notify OFCCP when changes result in the creation or elimination of one or more functional business units.
  • OFCCP loosened its 60-day deadline to approve FAAP requests, now stating the agency will generally make decisions within 60 days but may require additional time to gather more information.
  • OFCCP also eliminated the requirement that it only use information the contractor provides to evaluate its FAAP request. OFCCP did not state the other ways they may use information provided.

Regulations specifically addressing modifications to functional business units involving remote work employees were not included in the new announcement, but may be forthcoming in future iterations of the directive.


Action Items

  1. Review the updated directive here.
  2. Have FAAP procedures updated as applicable.
  3. Subscribers can call our HR Hotline at (833) 268-5531 for further assistance.

Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2022 ManagEase