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EEOC Ruling: Employers Must Report Pay Data by September 30, 2019

EEOC Ruling: Employers Must Report Pay Data by September 30, 2019

As a result of the court’s April 25, 2019 decision in National Women's Law Center, et al., v. Office of Management and Budget, et al., Civil Action No. 17-cv-2458 (D.D.C.), employers covered by EEO-1 reporting requirements must report Component 2 data for calendar years 2017 and 2018 by September 30, 2019. Component 2 data includes hours worked and pay information from employees' W-2 forms sorted by race, ethnicity, and sex.

The Equal Employment Opportunity Commission (“EEOC”) expects to begin collecting EEO-1 Component 2 data for calendar years 2017 and 2018 in mid-July 2019, and will notify filers of the exact date the survey will open as soon as it is available. 

EEO-1 Report filers should continue to use the currently open EEO-1 portal and must submit 2018 Component 1 data by May 31, 2019.  Component 1 data pertains to the number of employees who work for the employer by race, ethnicity, and sex.

The following employers are mandatory EE0-1 Report filers: companies with at least 100 employees, and federal contractors with at least 50 employees and a contract with the federal government of $50,000 or more. The EEOC uses information about the number of women and minorities companies employ to support civil rights enforcement and analyze employment patterns, according to the agency.

As the EEOC has explained, the EEO-1 Report is used to collect data from private employers and government contractors about their women and minority workforces, to support civil rights enforcement, and to analyze employment patterns, such as the representation of women and minorities within companies, industries, or regions.

If you have any questions or concerns EEO-1 reporting requirements and EEOC compliance generally, please do not hesitate to reach out to the Employment and Labor Practice Group at Laddey, Clark & Ryan, LLP: Thomas N. Ryan Esq. (, Ursula H. Leo, Esq. (, Jessica A. Jansyn, Esq. (, or Nicole C. Tracy, Esq. ( Our attorneys can also be reached by phone at (973) 729-1880.