The Equal Employment Opportunity Commission (EEOC) issued a proposal that would require employers to submit pay and work-hour data as part of their 2018 EEO-1 Reports.The EEO-1 filing mandate applies to employers with 100 or more employees and to certain federal contractors.

Known as “Component 2” of the annual EEO-1 Survey, the pay and work-hour data requirements were established in 2016 but blocked in 2017. In March 2019, a federal court reinstated them and ordered the EEOC to indicate how it would collect Component 2 data for the 2018 EEO-1 (which had already opened, for “Component 1” data only, on March 18, 2019). The EEOC filed its proposal on April 3, 2019. The court may still approve, modify or reject the plan.

Employers subject to EEO-1 reporting should:

  • Submit their 2018 EEO-1 “Component 1” data by May 31, 2019;
  • Prepare to submit “Component 2” information about their employees’ 2018 pay and work hours to the EEOC – potentially by September 30, 2019; and
  • Monitor the EEOC’s website for additional guidance.

If you have questions or need help, please contact one of our benefits consultants.