What needs to be filed

Federal contractors with 50+ employees and a single contract over $50K must file:

  • EEO-1 Component 1: workforce composition by race, gender, and job category
  • VETS-4212: protected veteran data
  • AAP (Affirmative Action Plan): updated annually if you're covered

The trap most teams fall into

Self-identification is voluntary, but you must invite every applicant and every employee at hire and annually thereafter. The invitation language is regulated — copy it from the OFCCP template, don't write your own.

Make it painless

  • Invite at apply. Build self-ID into the application form. Most candidates will skip it; that's fine. The invitation is the legal requirement, not the response rate.
  • Store separately from hiring data. Self-ID must not be visible to hiring decision-makers. Use a separate table with admin-only access (we use gigatec_ai_eeo_data exactly this way).
  • Aggregate-only reports. Never expose individual responses. Reports show counts and percentages.

Disparate impact in practice

The 4/5ths rule: if your selection rate for any protected group is less than 80% of the rate for the highest group, you have potential adverse impact. Compute this monthly, not annually — by the time the AAP is due, it's too late to course-correct.