Applicant Flow Log

Who needs one and what it records

Federal contractors used to keep applicant and hiring records by race, ethnicity and sex under the Executive Order 11246 rules enforced by the OFCCP. Those rules were revoked in January 2025 and the OFCCP rescinded the regulations effective October 26, 2026, so that requirement is gone. Contractors covered by VEVRAA still collect voluntary self-identification on protected veteran status and keep applicant and hire counts; the Section 503 disability self-identification requirement was removed in September 2026. Most large employers keep a full log anyway, because it is the simplest way to apply the four-fifths rule to their own funnel and to answer a discrimination charge with data under Title VII.

A typical log records, for each applicant and requisition: date applied, job and requisition number, source, self-identified race or ethnicity and sex (or "declined"), each stage reached, disposition reason, and hire date or rejection date. Self-identification must be voluntary and kept separate from the information hiring managers see. Use our applicant flow log template for a ready-made layout.

The Internet Applicant rule

For online hiring, the OFCCP's Internet Applicant rule (2006) defined who counts as an applicant. It was part of the EO 11246 regulations rescinded in 2026, but it is still a sound, defensible way to decide who belongs in your log. Under it, a person counts if all four apply:

1. They submitted an expression of interest through the internet or related electronic technology.
2. The contractor considered them for employment in a particular position.
3. Their expression of interest shows they meet the basic qualifications for the position.
4. They did not remove themselves from consideration before an offer.

Basic qualifications must be objective, set in advance and relevant to the job, such as "two years of call center experience" or "bilingual in English and Spanish". This matters in volume hiring, where an applicant tracking system may receive 2,000 applications for 40 seats. Contractors can use data management techniques, such as reviewing a random sample, to limit the pool considered, as long as the method is applied consistently.

Using the data

Compare selection rates by group at each stage, not just at hire. A screening question or assessment can cause adverse impact that a later stage hides. When a stage falls under the four-fifths rule threshold, review whether the step is job related and whether a less discriminatory alternative exists.

Retention: the two-year rule for race and sex records came from the EO 11246 regulations, which were rescinded effective October 26, 2026. Contractors covered by the veterans' (VEVRAA) or disability (Section 503) rules still keep personnel and hiring records for two years if they have 150 or more employees and a contract of at least $200,000 (VEVRAA) or $150,000 (Section 503), and for one year otherwise. Veteran applicant and hire counts and outreach assessments are kept for three years. Employers covered by Title VII and the ADA keep application and hiring records for at least one year under EEOC rules.