EEO-1 Pay Data Requirements Are Back On
Published by Eric A. Welter and Kimberly Kauffman on June 17, 2019
Employers who are required to file EEO-1 reports must now submit detailed pay data, by September 30, 2019.
We reported back in 2017 here how the Equal Employment Opportunity Commission (EEOC) requirement for employers to begin submitting employee pay data (“Component 2 data”) on a new EEO-1 form had been suspended indefinitely by the Office of Management and Budget (OMB). In March of this year, a D.C. federal court lifted the stay. The court ordered the EEOC to collect the pay data by September 30, 2019. Therefore, while employers are required to submit the typical EEO 1 data by May 31, 2019, they will have until September 30, 2019, to submit pay data for both 2017 and 2018.
The required Component 2 data includes data on employee pay and hours worked sorted by job category, pay band, race/ethnicity, and gender, and will have almost 24 times as many fields as the current EEO-1 Component 1 data form has.
Collecting this additional Component 2 may be a time-intensive process for employers, especially considering the amount of data that is required. While there is an appeal pending in the case discussed above, this appeal does not alter the September 30 deadline to submit pay data. Therefore, employers should begin figuring out its process to collect this additional pay data now. The EEOC expects to begin collecting Component 2 data by mid-July. In the meantime, employers should continue to check the EEOC’s website to determine if any additional developments occur.Topics: Affirmative Action and OFCCP Compliance, EEO-1, EEOC, Employment Discrimination and Harassment, Employment Litigation, Equal Employment Opportunity Commission, Office of Management and Budget, OMB