Which sponsors are required to have an Affirmative Action Program?

Equal Employment Opportunity

All sponsors who are not otherwise exempted are required to develop and maintain an Affirmative Action Program.  Each sponsor must develop its own Affirmative Action Program, even if employers participating in the sponsor’s program maintain Affirmative Action Programs.

The Equal Employment Opportunity (EEO) regulations provide two exemptions from the requirement to establish and maintain an Affirmative Action Program:

(1) programs with fewer than five apprentices; and

(2) programs already in compliance with an EEO program providing for affirmative action in apprenticeship.  Existing EEO programs must extend to apprentices and include the use of goals for any underrepresented group or groups; meet the requirements of title VII of the Civil Rights Act of 1964, as amended; and cover individuals with disabilities, or must meet the requirements of Executive Order 11246 and section 503 of the Rehabilitation Act.

These conditions only exempt sponsors from the requirement to maintain an Affirmative Action Program; sponsors are still required to comply with the other obligations in the EEO regulations, including the Equal Opportunity Standards applicable to all sponsors contained in 29 C.F.R. 30.3.  Please visit the EEO guide Avoiding Discrimination and Harassment in Registered Apprenticeship Programs for additional information.

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