The EEO-1 is a compliance survey mandated by Title VII of the Civil Rights Act of 1967 and requires certain employers to submit two types of data annually. Component 1 data includes the racial, ethnic, and gender composition of an employer’s workforce, while Component 2 data requires employers to report the hours worked and pay information of their employees by race, ethnicity, and sex. Based on the D.C. District Court’s recent decision in National Women’s Law Center, et al., v. Office of Management and Budget, et al., Civil Action No. 17-cv-2458 (D.D.C.), the deadline for employers to submit Component 2 data for the 2017 and 2018 calendar years to the Equal Employment Opportunity Commission (EEOC) is September 30, 2019. The deadline for submitting Component 1 data remains May 31steach year.
All private employers with over 100 employees must comply with EEO-1 reporting requirements. And if an employer has fewer than 100 employees, but is owned or affiliated with another company having 100 or more employees, that employer must also report. In addition, federal contractors and first-tier subcontractors who have 50 or more employees and a contract, subcontract, or purchase order with the federal government amounting to $50,000 or more must comply with the reporting requirements.
It is important to report this data to the EEOC so that they and the Office of Federal Contract Compliance Programs (OFCCP) can support civil rights enforcement and analyze employment patterns, such as the representation of women and minorities within companies. The OFCCP also uses the data to determine which employers should undergo compliance evaluations, such as those with a high likelihood of systemic discrimination.
Component 2 data can be filed through EEOC’s web-based portal. The URL for the portal is https://eeoccomp2.norc.org/.
This article was written by Emily Honet, Law Clerk
