Pursuant to a recent Court order overturning the Trump Administration’s efforts to overturn wage and hour reporting requirements adopted during the Obama Administration, employers who submit EEO-1 information have until September 30, 2019 to provide additional wage and hour information to the Equal Employment Opportunity Commission (“EEOC”). Specifically, the new EEO-1 “Component 2” form requires the collection of wage and hour data from both 2017 and 2018, organized by twelve (12) pay bands across ten (10) different job categories. This information then must be divided by the same racial, ethnic, and gender groupings that employers use when submitting demographic data in EEO-1 forms.
Now that the EEO-1 Component 2 pay data report portal has been open for a month – and with only five-plus weeks until the deadline – covered employers should start gathering the required information. Employers who wish to submit the data can do so manually by using an online form. Alternatively, as recently as August 15, 2019, employers can now upload responsive data via a specifically formatted .CSV file. With a few exceptions, employers with 100 or more employees are required to provide this Component 2 data to the EEOC by September 30, 2019. Unlike the requirements for regular EEO-1 data, however, federal contractors with fewer than 100 employees are not required to file a Component 2 report.
To learn more about the new EEO-1 “Component 2” requirements, including whether your company must comply with these reporting requirements, please contact a member of the Employment Law Team at AGG. Additionally, if you have any logistical questions regarding the submission of EEO-1 Component 2 data, the EEOC has set up a help desk available to offer support that can be reached at EEOCcompdata@norc.org or 877.324.6214. For more information, please click here.