Your company's first AAP should be completed within 120 days of the commencement of the original contract, and must be updated annually. The start date of your AAP year should fall within those first 120 days, but few company representatives have access to that knowledge, so if the date is unknown, the OFCCP suggests picking a date in your company's peak employment period. Most companies in general tend to choose a calendar year that begins on January 1.