Mandatory Job Listings

Federal contractors and subcontractors with a contract worth $200,000 or more have to comply with the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA), which mandates that open positions are listed with the appropriate Employment Service Delivery System (ESDS), also known as a state job bank.

Federal contractors and subcontractors are required to list all open positions with the exception of those that meet one or more of the following criteria:

1. An executive or top management position

2. A position that will be filled from within the contractor's organization

3. A position lasting 3 days or less

Jobs are to be listed concurrently with the appropriate ESDS, which means as long as positions are live on your organization's career page, they must remain open on the state job bank.

DCI Consulting is pleased to provide, as a free resource for everyone, an interactive map that links to the ESDS of every state, as well as the District of Columbia, the Commonwealth of Puerto Rico, Guam, and the Virgin Islands. DCI's ESDS Map.

The Vietnam Era Veterans' Readjustment Assistance Act remains an active law of the United States, despite the rescission of Executive Order 11246. The Office of Federal Contract Compliance Programs (OFCCP) was the main entity that monitored compliance with the nondiscrimination and affirmative action provisions of VEVRAA. While enforcement may move agencies, the mandatory job listing requirement remains.

The Jobs for Veterans Act (JVA) and the regulation implementing the JVA at 41 CFR 60-300.5 require that contractors list job openings with the appropriate Employment Service Delivery System. 

A contractor may satisfy the mandatory job listing requirement by submitting job listings to the appropriate Employment Service Delivery System in a variety of ways, including via mail, facsimile (FAX), electronic mail, or other electronic listings. The vast majority of state workforce agency job banks accept job listings via the Internet. Contractors may use third parties, such as private or nonprofit sector job banks, internet gateway and portal sites, and recruiting services and directories, to assist them with the transmission of job listings to the appropriate employment service delivery system. Ultimately, employers must list positions in a manner that is acceptable to each ESDS.

Federal contractors are required to maintain records and proof of postings for each position listed concurrently on the state job bank account for at least 2 years. In the event of an audit, DOL can request proof of job listings within the appropriate ESDS for all positions filled for the time frame in review.

From 2021 to 2024, Record Keeping or Support violations were found in 369 of the 640 compliance evaluations that closed in a Conciliation Agreement or Consent Decree, making it the second most likely violation.