Two years of pay and hours data due by 9/30/19 for EEO-1 Report

Not only must employers submit data on pay and hours worked during 2018 on the newly expanded EEO-1 Report by September 30, 2019, but they must also include pay and hours data from 2017. The requirement to provide pay and hours data applies to employers with 100 or more employees. The U.S. Equal Employment Opportunity Commission (EEOC)’s decision to require 2017 data along with the 2018 data is scheduled to be officially published in tomorrow’s Federal Register.
 
The EEOC expects its EEO-1 Report website will be ready to start receiving the pay and hours data in mid-July. As we recently reported in an Alert, the EEOC must submit progress reports to a federal district court judge every three weeks (National Women's Law Center v. Office of Management and Budget, D DC, order issued 4/25/19).
 
Tips: Employers with at least 100 employees have two EEO-1 Report deadlines to keep in mind this year. No later than May 31, 2019, these employers must submit “Component 1” of the EEO-1 Report, which is the traditional one-day workforce snapshot from a payroll date during the 4th quarter of 2018. Normally this snapshot would be due on March 31, but the deadline was extended to May 31 due to the partial federal government shutdown earlier this year. (Employers with at least 50 employees and $50,000 in federal contracts or subcontracts must also submit “Component 1” by May 31, 2019.) Then by September 30, 2019, employers with at least 100 employees must submit pay and hours data (“Component 2”) for calendar years 2017 and 2018. Vigilant will let members know when the EEOC provides further guidance and opens the agency’s portal for the pay and hours submission. In the meantime, if you have questions, Vigilant members should contact their employment attorney or affirmative action representative.

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