Last month, we informed our clients and colleagues of the recent, pending decision of whether or not qualifying employers would be required to submit Component 2 (collection of pay data) of the EEO-1 report by May 31, 2019 in addition to Component 1. “Component 2” of the EEO-1 report is intended to analyze pay data to determine any disparities or discrimination in pay, with the goal of improving upon this issue should any discrepancies come to light.
Last week, the EEOC finally released an update on the requirement to submit pay data. Employers who meet the EEOC’s reporting criteria are required to submit Component 2 of the EEO-1 report for both 2018 and 2017 no later than September 30, 2019.
Note: Employers are still expected to submit Component 1 of the EEO-report by the May 31, 2019 deadline.
The EEOC will begin accepting this component of the report in mid-July from employers who file the EEO-1 report annually who have more than 100 employees (in both the private sector and some federal/government contractors or subcontractors with more than 50 employees). Employers are expected to report pay data which includes hours actually worked and pay data gathered from their employee’s W-2 forms which will be categorized by race, ethnicity, and sex.
2019 EEO-1 Reporting
31, 2019: Component 1 data for 2018 is
14, 2019: Component 1 data for employers that requested a two-week extension is
15, 2019: Expected date employers can begin submitting Component 2 of the EEO-1
30, 2019: Component 2 data for 2017 and 2018 is due
Don’t wait until the last minute to get this data compiled; HRCentral is here to help you and your HR Department gather and submit data for your organization’s EEO-1 report. Contact us today for assistance in filing or for establishing a streamlined reporting process.
The May 31st deadline for submitting your organization’s EEO-1 report is just around the corner, which means for many of us that it is time to start finalizing and reviewing gathered information needed for annual EEO-1 reporting. In our last post, we discussed recent progress in the decision of whether or not employers additionally need to report on pay data for their employees, which provided a great opportunity to go back to the basics: EEO-1 Reporting 101.
The EEO-1 Report is a compliance survey that is mandated by federal regulations and statutes. Some of the most frequent questions asked pertaining to EEO-1 reporting include: who needs to file, what do you need to report and why, and when do you have to do all of this?
Who: The most commonly asked question with regards to EEO-1 reporting is who needs to file and what are the requirements for that organization? The criteria are as follows:
- Private employers/organizations with more than 100 employees (subject to certain exemptions); or
- Organizations with fewer than 100 employees who are owned by or are corporately affiliated with another company whose entire enterprise employs a total of 100 or more employees; or
- Federal government prime contractors (private employers) who are not subject to any exemptions, have 50 or more employees, and are first-tier subcontractors with 50 or more employees and a prime contract or a first-tier subcontract totaling $50,000 or more OR serve as a depository of government funds in any amount OR are a financial institution which is an issuing and paying agent for U.S. Savings Bonds and Savings Notes.
What: If the organization meets one of the above requirements, the survey requires them to submit employment data that is categorized by race/ethnicity, gender, and job category which the Equal Employment Opportunity Committee (EEOC) and the Office of Federal Contract Compliance Programs (OFCCP) use to support civil rights enforcement and analyze employment patterns, which in turn help them determine where the likelihood of systematic discrimination is the highest. This online submission must include:
- A report covering the principal or headquarters office;
- A separate report for each establishment employing 50 or more persons;
- A consolidated report that MUST include ALL employees by race, sex, and job category in establishments with 50 or more employees as well as establishments with fewer than 50 employees; and
- A list, showing the name, address, total employment, and major activity for each establishment employing fewer than 50 persons, must accompany the consolidated report.
When: Survey data must be pulled from one year’s pay period from either October, November, or December of the current survey year (e.g., for the 2018 report, pull data from November 1st, 2017 – November 1st, 2018). That data is then analyzed, compiled, and submitted into the EEO-1 form. The most convenient way to submit this data is through the EEOC’s website, in which all data is electronically entered and submitted. A copy of the form is available for your records after submission. EEO-1 reports must be submitted and certified no later than May 31st, annually.
These basic elements are just the beginning when it comes to EEO-1 reporting. There are a number of other steps, requirements, and methods of ongoing maintenance that go into reporting to ensure that the reporting process is accurate, conducted efficiently, and produces the desired outcomes. EEO-1 reporting can be a breeze or a hassle depending on established procedures and participation. As May 31st draws closer, contact us for assistance in gathering employee data, creating efficient processes for pulling information, or for filing on your behalf.