EEOC Opens On-Line Portal For Pay Data Reporting

July 23, 2019

We have previously reported on the long-running legal battle over the Obama-era requirement that large employers annually submit pay data by race/ethnicity and gender to the EEOC. The requirement, known as EEO-1 Component 2, was intended to be a tool for the EEOC to address group-wide wage disparities. The requirement was suspended during litigation, but earlier this year the federal judge presiding over the case ordered the EEOC to reinstate its pay data gathering.

For many years employers with 100 or more employees and federal contractors with 50 or more employees have had to file Component 1 of the EEO-1 form. On the Component 1 form, employers are required to breakdown their workforces by race/ethnicity and gender in 10 job categories.

Employers and federal contractors with 100 or more employees are now required to submit pay data on the newly-added Component 2 of the EEO-1 form. Component 2 of the new EEO-1 report will require employers to report aggregate W-2 compensation and hours worked in 12 pay bands for all employees reported in each of the Component 1 data fields.

Component 2 data must be submitted for 2017 and 2018 by September 30, 3019. On July 15, the EEOC opened up its on-line portal for reporting Component 2 data, and also published guidance to assist employers with the process of gathering and reporting the information.

A link to the EEOC resources for Component 2 data gathering and reporting is set forth below:

If you want to learn more about the EEO-1 reporting requirements please contact Daniel Tarlow ( or 617-456-8013) or Joseph Edwards ( or 617-456-8131), the authors of this alert.

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