The Department of Labor’s Office of Federal Contract Compliance Programs’ (OFCCP) final regulations defining "Internet Applicants" and setting forth new recordkeeping requirements went into effect on February 6, 2006. Although the regulations are already in effect, OFCCP has stated that it will exercise enforcement discretion for a period of 90 days. During that time, the department will not cite a contractor for purely technical recordkeeping violations where the contractor is taking reasonable steps to update its systems to comply with the rules and is maintaining records according to previously established procedures.
