Internet Applicant regulations published by the Office of Federal Contract Compliance Programs (OFCCP) go into effect on February 6, 2006. However, the OFCCP recently posted on its website that it will not cite employers for technical violations of the Internet Applicant recordkeeping requirements for 90 days after the effective date under the following two conditions:

(1) the employer demonstrates that it is taking reasonable steps to update its systems to comply with the rule, including a projected date of compliance, and

(2) the employer collects and maintains records according to the established procedures consistent with OFCCP’s recordkeeping requirements that preexisted the Internet Applicant final rule, i.e., 41 CFR 60-1.12.

The notice establishing the grace period can be found in the frequently asked questions (FAQs) section of the OFCCP website regarding Internet Applicants (www.dol.gov/esa/regs/compliance/ofccp/faqs/iappfaqs.htm#Q3).

If you have any questions regarding the grace period or about your obligations under the Internet Applicant regulations, please feel free to contact us.