Earlier this year the EEOC announced it would reinstate the collection of EEO-1 Component 2 data, thus requiring employers to submit pay data broken own by job category, sex, race, and ethnicity. The deadline for employers to submit Component 2 data for 2017 and 2018 remains September 30, 2019. The Component 2 EEO-1 Pay Data online filing system is available on the EEOC’s website along with a sample form, instructions for covered employers and FAQs. The Wagner Law Group’s Employment law attorneys are available to assist you with meeting the EEOC’s reporting requirements.
While this requirement remains in place for 2019, the agency has concluded that, moving forward, it will no longer collect EEO-1 Component 2 data. Without sound guidelines on how the agency would use the Component 2 pay-data, and due to its unproven utility, the EEOC has decided to reduce the administrative burden on employers to gather and submit the data after 2019. The potential remains for courts to possibly compel the EEOC to gather the data in future years, but time will tell.
As we reported in March, best practice remains for employers to review their pay practices, HRIS, and payroll systems to ensure that they can comply with the current EEO-1 reporting requirements. Employers should also consider conducting self-audits to determine if any impermissible pay discrepancies exist. For assistance with meeting the new EEO-1 reporting requirements or correcting pay discrepancy issues, please contact David Gabor or Katherine Brustowicz of the Wagner Law Group’s Employment Law practice.