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e-Alert – Action Required – Employers Must Submit EEO-1 Pay Data by Sept. 30

By July 17, 2019No Comments


A federal judge has ordered the Equal Employment Opportunity Commission (EEOC) to take all necessary steps to comply with changes to EEO-1 data collection obligations first announced in 2016 and stayed in 2017. These reinstated obligations increase the amount of information employers are required to collect and report to the EEOC, including pay data called “Component 2” data. Component 2 data includes wage and hour data for employees broken down by race/ethnicity and gender. On May 3, 2019, the EEOC announced that it will collect both 2017 and 2018 Component 2 data from covered EEO-1 filers by September 30, 2019.


The EEO-1 filing requirement generally applies to private employers with 100 or more employees and certain federal contractors. Covered EEO-1 filers — private employers, including federal contractors and first-tier subcontractors, with 100 or more employees — must submit both 2017 and 2018 Component 2 data (on compensation and hours worked) to the EEOC for calendar years 2017 and 2018 by Sept. 30, 2019.

Next Steps for Employers

  • The EEOC has announced that the online filing system for EEO-1 Component 2 data is open and they have begun sending system login information to employers via regular mail and email.
  • The web page for the filing system has been updated with employer FAQs and links to additional employer resources, such as a sample pay data collection form, an instruction booklet for filers, and a user’s guide. The EEOC has also set up a help desk, which may be reached at or 877-324-6214.
  • If you are a covered employer, the “Component 2” data for 2017 and 2018 is due on September 30, 2019. This new requirement does not change the current requirements for the EEO-1 demographic reporting (Component 1) that was due on May 31, 2019.
  • If you are interested in outsourcing the preparation and submission of your Component 2 data, please email us to learn more about this service.

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