Which sponsors are required to conduct annual reviews of personnel practices, and what should be included in those reviews?

The Affirmative Action Program is the general activities that sponsors engage in to support equal opportunity in recruitment and hiring of all qualified individuals.

The Affirmative Action Plan is the written documentation of these activities.  Sponsors do not need to submit the Plan to the Registration Agency but must make it available upon request, including during compliance reviews.

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Yes. The exemption is based on the total number of apprentices per sponsor – not per employer.  Thus, if the number of apprentices in the sponsor’s program is five or more, the sponsor is required to maintain an Affirmative Action Program.  Regardless of the number of employers or the distribution of apprentices across them, if the total number of apprentices is five or more, the sponsor is required to have an Affirmative Action Program.

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The deadline for sponsors registered with the national Office of Apprenticeship to put an initial Affirmative Action Program in place is two years after a program’s registration date, or two years from the date the program registers its fifth apprentice – whichever is later.  The Affirmative Action Program deadline for sponsors registered with State Apprenticeship Agencies depends on their state Equal Employment Opportunity plan.

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No. Each sponsor simply needs to maintain an up-to-date plan and make it available to the Registration Agency upon request, including during its compliance review. 

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