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Labor and Employment Alert: Urgent Reminder: Employers Have Until September 30 to Submit EEO-1 Pay Data

As we previously reported, the Equal Employment Opportunity Commission (EEOC) has been ordered to collect to employers’ EEO-1 Component 2 compensation data.  This data must be submitted by September 30, 2019. 

Employers, including federal contractors, with 100 or more employees are required to submit pay and hours worked data for calendar years 2017 and 2018.  In determining whether the 100-employee threshold is met, an employer must consider both its headquarters and all other establishments.  Companies with more than one establishment are required to report Component 2 data for all establishments, including those having fewer than 100 employees. Federal contractors and other employers with fewer than 100 employees are not required to report Component 2 compensation data.

Employers select a pay period between October 1 and December 31 in 2017 and in 2018 – the workforce snapshot period – to provide the Component 2 data.  An employer does not have to select the same workforce snapshot period each year. 

The Component 2 data must be uploaded to the EEOC’s web portal:

Additional resources for employer filers, including Frequently Asked Questions, Sample Data Collection Form, Instruction Booklet for Filers, User's Guide, and Fact Sheet are available at

On May 3, 2019, the Department of Justice filed a notice of appeal in the case. However, the notice of appeal does not stay the district court orders or alter employers’ obligations to submit the Component 2 data by September 30.

Contact your Vorys lawyer if you have questions about the new Component 2 requirements or the impact it may have on your current EEO-1 reporting.

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