When are Federal contractors and subcontractors required to develop a written Affirmative Action Plan (AAP)?

Each federal contractor/subcontractor subject to a written Affirmative Action Plan (AAP) is required to develop the AAP within 120 days from the commencement of the Federal contract. The Affirmative Action Plan must be updated annually.

As a Prime Contractor, am I required to make sure that the vendors and suppliers with whom I am doing business develop a written AAP?

No. You are not required to ensure that your vendors and suppliers develop and maintain written AAPs. The requirement under the regulations is that each contractor and subcontractor include the EO clause in each of their subcontracts and purchase orders.