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If you're on this page, you've decided that your organization needs to develop an AAP. Now, let's consider timelines and deadlines.

The timeline for developing your AAP depends on whether you’re registered with OA or with an SAA. And it depends on where you are in the compliance-review cycle. There are even different deadlines for the different components of the AAP.

In this course, we’ll review the timelines and deadlines for programs that are registered with OA. Because these might be different for sponsors who register their programs in SAA states, you’ll need to contact your SAA to ascertain your AAP compliance deadlines.

The Initial Written AAP

The deadline for completing your initial written AAP is two years after your registration date (for convenience, we’ll refer to this as your two-year registration anniversary). Here are the components of your initial AAP:

Initial workforce analyses for race/sex/ethnicity (but not the availability analyses) and for IWDs;
Invitations to apprentices and applicants to self-identify as IWDs; and
First annual review of personnel processes.

You do not have to complete the remaining components of an AAP—the availability analyses for race/sex/ethnicity and setting of utilization goals – until the first compliance review by your Registration Agency that occurs after your two-year registration anniversary. That is because OA does not expect you to conduct these steps alone; the regulations contemplate that you will receive technical assistance in conducting them from your Registration Agency as part of your compliance reviews.

Compliance Reviews

You may not be familiar with “compliance reviews.” They are the audits that the Registration Agency performs of each RAP’s compliance with the Apprenticeship EEO regulations. Per 29 CFR § 30.13(a):

An EEO compliance review may consist of, but is not limited to, comprehensive analyses and evaluations of each aspect of the apprenticeship program through off-site reviews, such as desk audits of records submitted to the Registration Agency, and on-site reviews conducted at the sponsor’s establishment that may involve examination of records required under this part; inspection and copying of documents related to recordkeeping requirements of this part; and interviews with employees, apprentices, journeyworkers, supervisors, managers, and hiring officials.

Registration agencies are required to conduct compliance reviews “regularly . . . and when circumstances so warrant.” The review cycle varies by Registration Agency. Historically, OA reviewed programs for EEO compliance about once every five years.

Backstory on These Deadlines

Hear our expert provide some context on why these compliances deadlines are so complex!

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