An entire industry has sprung up around fulfilling these job posting requirements.  OFCCP’s regulations have been updated to account for the use of these private, 3rd party job listing services.  Use of such services will be considered satisfactory as long as the 3rd party service is posting in a “manner and format permitted by the ESDS.”  If you use a 3rd party service, you should ensure that your agreement contains such a requirement.

Compliance with the job listing requirements is ultimately the responsibility of the Federal contractor, not the 3rd party.  If your company uses a 3rd party job listing service, it is in your best interest to ensure they are meeting this obligation for you.  The best way to do this is to perform an audit or spot check of current listings.  If you can verify that the postings sent to the 3rd party are making it to the ESDS’ final job board, then you should be in good shape.  Searching the ESDS website for your company’s name is a good way to start this process.