# OFCCP Job Posting Requirements: A Practical Compliance Guide for Federal Contractors
If you’re searching for **OFCCP job posting requirements**, you likely want a clear answer to two questions: **(1) what must federal contractors do when posting jobs and recruiting, and (2) what documentation proves compliance during an audit?** This guide breaks down the core **OFCCP compliance job posting requirements**, including the commonly misunderstood “**5 day job posting requirements**,” recordkeeping, and applicant tracking practices that support affirmative action obligations.
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## What Are OFCCP Job Posting Requirements?
The Office of Federal Contract Compliance Programs (OFCCP) enforces federal contractor equal employment and affirmative action obligations under:
- **Executive Order 11246** (race/sex protections and affirmative action for federal contractors)
- **Section 503 of the Rehabilitation Act of 1973** (affirmative action for individuals with disabilities)
- **VEVRAA** (affirmative action for protected veterans)
While OFCCP does not publish one universal “post your job for X days” rule for every employer and every role, it *does* expect federal contractors to recruit in ways that support **equal opportunity and affirmative action**, follow any applicable **state job bank listing obligations**, and maintain records that demonstrate fair access and non-discriminatory selection.
For broader EEO context and the goals behind these rules, see SwiftSDS’s overview of how **[employment opportunity and the EEO strives to](/laborposters/federal-laws/as-it-pertains-to-employment-opportunity-the-eeo-strives-to)** reduce barriers and promote consistent hiring practices.
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## Core OFCCP Recruiting Requirements That Affect Job Postings
### 1) “Equal Opportunity Employer” language and accessibility
A compliant posting process should ensure:
- Job ads and career sites are accessible and usable by applicants with disabilities (Section 503 expectations).
- Job postings and recruiting communications avoid discriminatory language.
- EEO statements are consistent and applied across requisitions.
If you’re formalizing disability-related recruiting processes (including accommodation workflows), SwiftSDS’s resources on **[ADA HR](/laborposters/federal-laws/ada-hr)** and **[ADA forms for employers](/laborposters/federal-laws/ada-forms-for-employers)** can help align hiring operations with compliance documentation.
### 2) Outreach and recruitment beyond “who you already know”
OFCCP evaluates whether contractors take meaningful steps to reach diverse candidate pools—especially for protected veterans and individuals with disabilities. Practical examples include:
- Using multiple recruiting sources (job boards, community organizations, workforce agencies, professional associations)
- Maintaining relationships with vocational rehab and veteran organizations (where applicable)
- Tracking outreach effectiveness and adjusting sources over time
### 3) Consistent, documented selection procedures
OFCCP audits frequently focus on whether selection decisions were made using:
- Job-related criteria tied to the position
- Consistent screening steps
- Documented reasons for dispositioning applicants (i.e., why someone was not selected)
This is where compliant job posting meets compliant recruiting: the posting is only the beginning; your **workflow and records** are what prove compliance.
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## The “5 Day Job Posting Requirements” (What Employers Usually Mean)
Many HR teams search for **5 day job posting requirements** in connection with OFCCP because of internal job posting rules, collective bargaining agreements, or state/local transparency practices. **OFCCP itself does not impose a universal “post every job for five days” rule across all contractors and all roles.**
However, there are two areas where “five days” commonly shows up in practice:
### 1) State job bank listing requirements (VEVRAA / ESDS)
Under **VEVRAA**, covered contractors generally must list most job openings with the appropriate employment service delivery system (ESDS), typically the state workforce agency job bank. States may have their own timing/format practices. Employers should:
- Confirm whether the opening is covered or exempt (e.g., certain executive/senior roles, internal moves, positions lasting three days or less may fall into exemptions—consult counsel for specifics)
- Keep proof of listing and referral activity
### 2) Internal policy and audit defensibility
Some contractors adopt a **standard minimum posting window** (often 5 business days) to support consistent access, reduce favoritism risk, and create clean records for audits—particularly for promotions and transfers. Even if not strictly required by OFCCP, a consistent posting window can improve defensibility when OFCCP reviews selection patterns.
Location-specific rules can also influence posting practices. If you operate in states with additional posting norms, cross-check your jurisdiction pages like **[Federal (United States) Posting Requirements](/postingrequirements/us)** and your state pages (e.g., **[Ohio (OH) Labor Law Posting Requirements](/postingrequirements/us/oh)**). For California-specific job posting considerations, SwiftSDS also covers **[whether employers are required to post job openings in California](/laborposters/digital-posters/are-employers-required-to-post-job-openings-california)**.
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## Affirmative Action Job Posting Requirements: What to Do (Actionable Checklist)
Below is a practical checklist for **affirmative action job posting requirements** and **OFCCP recruiting requirements** that HR teams can implement immediately:
### 1) Standardize requisition content
Include:
- Accurate job title, essential functions, qualifications
- Clear “minimum” vs. “preferred” qualifications (avoid inflating requirements)
- Work location and schedule expectations (important for consistent candidate evaluation)
- EEO tagline and accommodation language (consistent with your policies)
### 2) Use consistent posting channels and retain evidence
For each requisition, retain:
- Where it was posted (career site, job board, ESDS/job bank, internal board)
- Posting dates and screenshots or system logs
- Job board invoices or confirmations (if used)
- Recruiter notes on outreach efforts
### 3) Track applicants and dispositions in your ATS
OFCCP audits often hinge on applicant-level data. Ensure your ATS captures:
- Applicant source
- Stage movement and disposition reason codes
- Interview notes and selection rationale tied to job-related criteria
### 4) Apply accommodation-ready recruiting steps (Section 503)
Operationalize:
- A clear accommodation request pathway during application and interview stages
- Internal process documentation (forms, email templates, escalation steps)
- Training for recruiters and hiring managers
### 5) Maintain required postings and labor law notices
While not “job postings,” required workplace notices often appear in OFCCP compliance discussions because they demonstrate baseline labor law compliance and HR infrastructure. Consider using a centralized approach like SwiftSDS’s **[compliance poster service](/laborposters/workplace/compliance-poster-service)** to keep workplace postings current.
When discussing federal notice obligations, it’s also useful to maintain access to required postings like **[Employee Rights Under the Fair Labor Standards Act](https://h64afuvta1tdgdma.public.blob.vercel-storage.com/posters/1767652262511-minwagep.pdf)** (and the appropriate version for your workforce).
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## Recordkeeping: What OFCCP Expects You to Be Able to Produce
During a compliance evaluation, contractors should be ready to produce documentation showing:
- Job requisitions and job descriptions
- Posting locations and dates (including state job bank listings where required)
- Applicant flow logs and demographic data collection processes (where applicable)
- Interview and selection documentation
- Outreach efforts and assessments (especially Section 503 and VEVRAA-focused outreach)
- Policies and training materials supporting consistent recruiting
Also remember: federal labor compliance operates as a system. HR teams often benefit from reviewing broader worker protections and internal policies alongside OFCCP practices, such as SwiftSDS’s overview of **[5 rights of workers](/laborposters/federal-laws/5-rights-of-workers)**.
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## Common Pitfalls That Trigger OFCCP Scrutiny
- **Inconsistent posting windows** (some roles posted publicly, others filled quietly without documentation)
- **Unstructured disposition reasons** (e.g., “not a fit” without job-related explanation)
- **Missing proof of job bank listings** where required under VEVRAA/ESDS expectations
- **Qualification inflation** that disproportionately screens out protected groups
- **No measurable outreach tracking** (especially for disability and veteran outreach)
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## FAQ: OFCCP Compliance Job Posting Requirements
### Do federal contractors have to post every job publicly?
Not always, but you should assume OFCCP will expect a **consistent, documented recruiting process** and—where applicable—compliance with **state job bank listing requirements** under VEVRAA. Internal-only fills and direct placements can create risk if you can’t show fair access and job-related selection criteria.
### Is there an OFCCP “5 day job posting requirement”?
There is no universal OFCCP rule requiring all jobs be posted for five days. The “5 day” concept typically comes from internal policies, CBAs, or defensible best practices. Some roles may also involve timing expectations tied to state job bank listing practices—confirm by role and location.
### What’s the most important thing to document for OFCCP recruiting requirements?
Maintain **end-to-end audit-ready records**: where the job was posted, the posting dates, applicant sources, disposition reasons, and the job-related rationale for selection decisions. If it isn’t documented, it’s hard to defend during an audit.
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## Next Step for SwiftSDS Readers
If you’re aligning job postings with broader compliance obligations, start by confirming your baseline labor posting rules on the **[Federal (United States) Posting Requirements](/postingrequirements/us)** page, then build a standardized recruiting and recordkeeping workflow that supports OFCCP audit readiness.