EEOC Pay Data Reports Due September 30

September 2019

Employers with 100 or more employees are required to file pay data for 2017 and 2018 with the Equal Employment Opportunity Commission (EEOC) by September 30, 2019. Technically known as “EEO-1 Component 2” data, the reporting requirement for EEO-1 filers complies with a ruling in the case National Women’s Law Center, et al. v. Office of Management and Budget, et al . Data for full and part-time workers must be included.

This expanded data collection process was part of the EEOC’s effort to achieve gender pay parity. The regulations require employment data to be categorized by race/ethnicity, gender and job category, and to include compensation. The Equal Pay Act of 1963 and Civil Rights Act of 1964 both require that men and women in the same workplace receive equal pay for equal work.

In a Federal Register notice dated September 11, however, the EEOC indicates that it does not intend to renew Component 2 filing requirements in future years. After conducting an updated cost / benefit analysis, the EEOC determined that the “unproven utility” of the pay data “is far outweighed by the burden imposed on employers that must comply with the reporting obligation.” An online portal can be accessed at

Click on the link to read an article that Steve Darden wrote for the Business Journal on pay equity (see page 30 of the issue). Contact a member of the Labor & Employment section if you have any questions on this or any other matter.

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