By Katherine Brustowicz, Denise Chicoine, David Gabor, Johanna Matloff, or Virginia Peabody (Senior Consultant)
What is EEO-1 Reporting?
An EEO-1 Report is a document submitted to the Equal Employment Opportunity Commission (“EEOC”), a federal agency to which covered organizations must report specific demographic characteristics of their workforce, such as race, ethnicity, and sex. EEO-1 reports are filed annually.
Who Needs to File?
- Private employers with 100 or more employees.
- Businesses with under 100 employees, if they are part of a group with a combined total of 100 or more employees.
- Institutions with at least 50 employees that manage government funds or handle U.S. savings bonds and notes.
- Federal contractors with 50 or more employees and a contract of $50,000+.
Filing Deadline.
The 2024 EEO-1 reporting portal opened on Tuesday, May 20, 2025. The deadline to file is Tuesday, June 24, 2025.
How To File an EEO-1 Report?
Filers should visit http://www.eeocdata.org/eeo1 to access the EEO-1 Component 1 Online Filing System (OFS).
The EEOC & Executive Orders.
The EEO-1 Report serves as a data collection tool for both employers and the EEOC. The report can be used to identify potential patterns of disparate impact and potential disparities within an employer’s workforce. It can also be used to ensure compliance with fair employment practices and as an opportunity for employers to take proactive measures to address any issues.
On April 23, 2025, President Trump issued an executive order titled “Restoring Equality of Opportunity and Meritocracy.” This order directed all federal agencies, including the EEOC, to deprioritize claims and cases that challenge neutral practices with disparate outcomes based on race, sex, or other protected characteristics. It also revoked certain Presidential approvals of regulations implementing Title VI that were promulgated by the Department of Justice in 1966 and 1973. These regulations prohibited specific types of discriminatory actions by employers receiving federal financial assistance based on race, color, or national origin. The regulations also prohibited the use of neutral policies or practices that have a discriminatory effect on a protected group and required affirmative action to overcome the effects of prior discrimination.
Andrea Lucas, Acting Chair of the EEOC, acknowledged in a recent statement that the EEOC is an executive branch agency and, therefore, plans to comply fully with President Trump’s Executive Order deprioritizing disparate impact claims and prioritizing intentional discrimination claims. Lucas reiterated that the EEOC is committed to preventing and combating unlawful race and sex discrimination, stating that discrimination clearly remains impermissible. It is not entirely clear how the EEOC will differentiate between the types of discrimination claims pending before it, particularly where many charges include claims of both disparate impact and disparate treatment. In addition, while EEO-1 Reports have been used to identify patterns of disparate impact, which will no longer be a priority for the EEOC, they also could be used to identify claims of intentional discrimination. Employers should continue to carefully prepare and submit EEO-1 Reports and proactively address issues where appropriate, even though the EEOC plans to deprioritize disparate impact discrimination claims.
Need Help with EEO-1 Reporting?
If you need assistance with EEO-1 reporting, whether ensuring compliance, preparing and submitting your report, or navigating the statutory and regulatory requirements, our Employment Law and Human Resources Team at The Wagner Law Group is here to help. Contact Katherine Brustowicz, Denise Chicoine, David Gabor, Johanna Matloff, or Virginia Peabody for guidance and a streamlined filing process.