How CareerCircle Helps Employers Show Good Faith During an OFCCP Compliance Audit
How CareerCircle Helps Employers Show Good Faith During an OFCCP Compliance Audit
For many Talent Acquisition and compliance leaders, the phrase OFCCP compliance audit tends to trigger the same reaction. There is urgency, some uncertainty, and usually a quick internal check of whether current outreach efforts will actually hold up under review.
And honestly, that reaction makes sense.
Over the past several years, enforcement priorities have shifted and the expectation around documented good faith efforts has become more visible. Teams are being asked to show measurable outreach to individuals with disabilities and protected veterans, often without additional time or headcount to support the work.
The good news is that audit readiness does not require building entirely new processes from scratch. In many cases, organizations are already doing pieces of the right work. The gap is usually visibility, consistency, and documentation.
Let’s level set what OFCCP is looking for and where CareerCircle can help employers strengthen their position.
A Quick Level Set: What an OFCCP Compliance Audit Actually Examines
The Office of Federal Contract Compliance Programs (OFCCP) is both an enforcement agency and a civil rights agency. They are responsible for ensuring federal contractors meet their Equal Employment Opportunity obligations (EEO). This includes requirements under Executive Order 11246, Section 503 of the Rehabilitation Act, and VEVRAA.
When an OFCCP compliance audit begins, the agency is not only checking whether policies exist on paper, but compliance officers are evaluating whether contractors can demonstrate credible good faith efforts to recruit, engage, and support protected groups.
In recent years, Section 503 focused reviews have placed even greater attention on disability inclusion practices. These reviews look closely at outreach activity, reasonable accommodation processes, accessibility of application systems, and leadership engagement.
The expectation is not perfection. But organizations do need to show that their efforts are consistent, measurable, and intentional.
Where Employers Commonly Feel Friction
In the current talent acquisition landscape, we often see teams that are doing many of the right things but still feel exposed when audit conversations begin.
A few patterns show up repeatedly.
Outreach is happening but not well documented.
Jobs may be posted across multiple channels, but reporting is fragmented or difficult to pull together quickly.
Job distribution is inconsistent.
Some roles get broad visibility while others are posted more selectively, which can create risk during a compliance review.
Self-ID rates remain lower than expected.
With over 70% of disabilities being non-apparent, candidate trust and experience play a major role in Self-ID and disclosure.
Accommodation concerns are still misunderstood.
There is still a persistent myth that disability hiring creates significant cost or operational burden, even though most accommodations are low or no cost.
Data lives in too many places.
Talent acquisition teams are often asked to produce audit-ready reporting from systems that were never designed to work together.
None of these challenges are unusual. But they do highlight why structure and visibility matter so much when demonstrating good faith.
What Strong Good Faith Efforts Actually Look Like
From a Section 503 standpoint, OFCCP is generally looking for evidence that contractors are taking proactive, consistent steps to reach and support individuals with disabilities.
Strong programs typically demonstrate:
-
Broad and consistent job outreach
-
Accessible application experiences
-
Clear reasonable accommodation processes
-
Leadership support for inclusion efforts
-
Measurable engagement data
-
Ongoing education for hiring teams
This is where many organizations realize that intent alone is not enough. You need the ability to show the work.
How CareerCircle Helps Employers Strengthen Audit Readiness
CareerCircle was built to help employers move from manual, fragmented outreach to a more structured and defensible approach. The goal is not just visibility, but visibility that can be measured and explained if questions arise.
Automated Job Distribution With Built-In Optimization
One of the most consistent best practices we use in our client consultation is simple—post all eligible jobs, not just the ones that feel like an obvious fit.
Selective posting can unintentionally create gaps in outreach and visibility. CareerCircle’s automated job scrape helps address this by pulling U.S. based roles directly from employer career sites and distributing them daily to our network of more than 220,000 registered members.
Just as important, this is not a set-it-and-forget-it process.
CareerCircle reviews and optimizes employer job feeds on an ongoing basis. If certain roles or locations consistently show little to no engagement, our team evaluates the data and works with partners to refine distribution strategy where appropriate. The goal is to maintain broad visibility while also ensuring the activity remains meaningful and defensible.
For employers thinking ahead to an OFCCP compliance audit, this combination of full job coverage and ongoing optimization helps demonstrate intentional, sustained, good faith effort over time.
Accessibility That Strengthens the Candidate Experience
Visibility alone is only part of the equation. OFCCP is also paying closer attention to whether candidates can actually access and navigate the application experience.
This is an area where many employers run into challenges, especially when career sites and ATS platforms were not originally built with accessibility in mind.
CareerCircle helps address this gap by hosting employer opportunities within our accessibility-focused platform. Our site is designed to align with the Web Content Accessibility Guidelines (WCAG 2.2) Level AA and is regularly reviewed through a combination of automated and manual testing, including feedback from users who rely on assistive technology.
In practice, this gives employers an additional layer of support. Even if accessibility improvements are still in progress within the employer’s own ATS environment, their roles are also being distributed through a platform built with inclusive access in mind.
Accessibility is always an evolving target, and no single solution eliminates every barrier. What matters most is demonstrating sustained, good faith effort to provide equitable access to opportunities. Hosting jobs within an accessibility-conscious ecosystem helps reinforce that commitment.
Employers who want to explore the full technical details can review CareerCircle’s accessibility statement here.
Data That Holds Up Under Review
If an audit occurs, employers need more than a general statement of effort. They need clear reporting that shows how candidates engaged with their roles.
CareerCircle provides detailed analytics that help close this loop, including:
-
Job views and apply clicks
-
View to apply ratios
-
UTM tracking for campaign visibility
-
Promoted job performance
-
Location level reach
-
Applicant data to support ATS reconciliation
-
Sourcing and engagement activity
For many teams, this becomes one of the biggest confidence builders. Instead of scrambling to assemble reports, they can point to a structured record of ongoing outreach.
Virtual Career Fairs That Support Documented Outreach
In addition to steadfast job visibility, many employers are also looking for more direct engagement opportunities with disability talent communities.
CareerCircle’s Virtual Career Fairs provide another structured way to demonstrate proactive outreach. These events create dedicated touchpoints between employers and job seekers and generate measurable engagement data that can support good faith documentation.
From a compliance standpoint, VCF participation can help show:
-
Intentional community engagement
-
Live candidate interaction
-
Event-level performance metrics
-
Ongoing investment in disability/military outreach
For many Talent Acquisition teams, this becomes a helpful complement to automated job distribution. It shows that outreach is not only passive but also actively supported through intentional engagement activities.
View Current Virtual Career Fairs
InclusiveU: Education That Supports Compliance Culture
Technology alone does not solve for audit readiness. OFCCP also looks closely at whether organizations are building internal awareness and consistency around disability and military inclusion.
CareerCircle’s InclusiveU education program helps support this effort through employer-facing webinars and trainings that are eligible for SHRM PDC credits. These sessions help TA and HR teams better understand topics such as accessibility, accommodations, and inclusive hiring practices.
You do not have to be a disability expert. But your teams do need a shared baseline and a repeatable playbook.
Learn More About InclusiveU and our SHRM Trainings
Letter of Good Standing and Partnership Documentation
Another area that can create stress during an audit is pulling together a clear narrative of partnership activity.
CareerCircle can provide a Letter of Good Standing that highlights the tenure and engagement points of the relationship. This can include:
-
Training/Event participation
-
Consultation touchpoints
-
Outreach activity
-
Hiring outcomes where available
-
Ongoing partnership milestones
For many employers, having this documentation readily available helps simplify audit conversations and reinforce the consistency of their efforts.
Turning Compliance Into a Sustainable Strategy
OFCCP compliance does not have to feel reactive or overly complex. In many cases, the organizations that feel most confident during audits are simply the ones that have built steady, well documented processes over time.
When outreach is consistent, data is centralized, and teams understand their role in disability inclusion, good faith efforts become much easier to demonstrate.
CareerCircle’s focus is to help employers build that structure in a way that supports both compliance goals and real talent outcomes. Because at the end of the day, the strongest programs are the ones that do both.
