Posted: May 8, 2019 

Private sector employers (including non-profit employers) with at least 100 employees and certain federal contractors are required to file EEO-1 reports to the Equal Employment Opportunity Commission (EEOC) each year.  Due to an order issued on April 25, 2019, by the United States District Court for the District of Columbia, employers required to file EEO-1 reports must now file additional employee pay data for years 2017 and 2018 as part of their filing obligations.  This is known as EE0-1 “Component 2” filing.  The required date for the additional filing is by September 30, 2019.

The EEO-1 filing process is split into two distinct requirements. Component 1 has been in effect since the 1960s and is the basic requirement that employers report the number of individuals employed by job category, sex, race, and ethnicity.  Component 1 is to be submitted and certified by May 31, 2019.  Component 2 is an Obama-era regulation designed to combat gender and racial pay gaps.  While the Trump Administration sought to end the requirement that employers report pay data, the decision was challenged in federal court.  The Trump Administration was found to have used a procedurally invalid process to remove the regulation.  Thus, the Court reinstated EEO-1, Component 2, thereby requiring employers to submit the pay data.

While September 30 may seem like a long way off, the information sought in Component 2 is somewhat burdensome.  Employers are required to file not only total annual wages paid to employees but also their work hours.  Fortunately, like Component 1, Component 2 material can be submitted online via the EEOC’s website. 

If uncertain about your business’s EEO-1 filing requirements or any other labor and employment concerns, reach out to the attorneys at Masud Labor Law Group for expert, individualized consultation.

This article is published by the Masud Labor Law Group, and is intended as general information only.  This article is not intended to provide legal advice or opinion, as such advice may only be given when related to specific fact situations.  Questions or comments concerning this article should be directed to the Masud Labor Law Group, 4449 Fashion Square Blvd., Ste. 1, Saginaw, Michigan, 48603, (989) 792-4499.  E-Mail: .(JavaScript must be enabled to view this email address). ©Masud Labor Law Group 2011.  All rights reserved.  Reproduction of this article in whole or in part, without express permission from the Masud Labor Law Group is prohibited.

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