Executive Summary: EEOC and OFCCP have issued a new workplace poster, and the end of the year is quickly approaching. Now is the time for federal contractors to start planning for 2023 compliance with OFCCP obligations including affirmative action plan (AAP) development, annual compliance certification, and annual EEO and affirmative action training. Additionally, Contractors should stay on top of regulatory developments.

• 2023 is just around the corner. Federal Contractors with a January 1-December 31, AAP year should begin gathering data and other necessary information so that they are prepared to begin the AAP development process right after the new year. This is particularly important for those contractors with establishments on the current scheduling list. OFCCP will not extend the deadline for submitting a response to a scheduling letter except in a few extraordinary circumstances. If you are not sure whether you are on an active scheduling list, please contact your FordHarrison attorney.
• Now is also the time to review whether there are any gaps in training for recruiters and managers. Refresher training on proper dispositioning of applicants and OFCCP affirmative action and non-discrimination obligations are critical components to any compliance program.
• OFCCP's revised Pre-Determination Regulation is expected to be issued shortly. Keep an eye out for an alert from FordHarrison's Affirmative Action Practice Group outlining changes to the regulation and implications...

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