Important EEO-1 Component 2 Deadline Approaching This Month

An important deadline approaches for those employers required to file the EEO-1 survey – which generally includes employers with at least 100 employees. In April 2019, a federal court ordered the Equal Employment Opportunity Commission (EEOC) to collect “Component 2” data for the EEO-1, with that data due from employers on September 30, 2019. Component 2 reports data regarding summary compensation and hours worked for purposes of tracking pay equity across the demographic reporting categories.  A reporting employer draws this data from a single, employer-selected pay period between October 1 and December 31 of the reporting year.

The chart below summarizes recent, upcoming, and anticipated deadlines and information for the EEO-1’s Components 1 and 2.

Employers must submit the Component 2 data electronically through the EEOC’s Component 2 EEO-1 Online Filing System, or by submitting a data file to the EEOC.  An acquiring or newly merged company might also be responsible for reporting data of newly-acquired employees for whom they did not previously report and so should solicit legal counsel to confirm its Component 2 reporting duties for such employees. Both full and part-time employees’ data are included in EEO-1 reporting.

The EEOC has issued guidance to help employers submit the data, including a sample form and an instruction booklet. Employers should consult with counsel to ensure compliance with these new data submission requirements.

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