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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.
EEO-1 Component
Due Date
Information
Pay Period
Component 1
2018: May 31, 2019
2019: March 31, 2020
Gender, race/ethnicity, & job category for all
employees.
Any pay period between Oct. 1 and Dec. 31, for both 2017 and
2018.
Component 2
2017 & 2018: September 30, 2019
2019: March 31, 2020 (starting next year, Components 1 and 2
will likely be due on the same date)
W-2 wage information & total hours worked for all employees
by gender, race/ethnicity, job category, and pay.
Any pay period between Oct. 1 and Dec. 31, for both 2017 and
2018. Does not have to be the same pay period as used for Component
1.
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.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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