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

The apprenticeship Equal Employment Opportunity regulations require certain Registered Apprenticeship Program sponsors to develop Affirmative Action Programs.  An Affirmative Action Program assists sponsors in detecting, diagnosing, and correcting any barriers to equal opportunity that may exist in its apprenticeship program.  Further, an Affirmative Action Program is designed to ensure equal opportunity and prevent discrimination in apprenticeship programs.  A sponsor’s written Affirmative Action Plan states the specific steps sponsors will take to ensure all qualified applicants and apprentices receive equal opportunity to be selected for – and succeed in – Registered Apprenticeship Programs.

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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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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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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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