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ARTICLE · 08 MAY 2025

EEO-1 Reporting (Maybe) — Get Ready Nonetheless!!

Foley & Lardner LLP
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On April 15, 2025, the Equal Employment Opportunity Commission (EEOC) sought approval of its 2024 EEO-1 Component 1 data collection. The EEOC's new proposed 2024 EEO Component 1 Instruction Booklet...

United StatesEmployment and HR
Jeffrey Kopp
Jeffrey Kopp
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On April 15, 2025, the Equal Employment Opportunity Commission (EEOC) sought approval of its 2024 EEO-1 Component 1 data collection. The EEOC's new proposed 2024 EEO Component 1 Instruction Booklet (the "Booklet") changes some reporting obligations for employers. If approved, employers will have from May 20, 2025, to June 24, 2025, to file their reports. Private employers with at least 100 employees must file the EEO-1 report annually. In addition, federal government contractors with 50 employees previously were required to file EEO-1 reports. What is less clear is whether government contractors with less than 100 employees will have to file their EEO-1 report. The EEOC's proposed Instruction Booklet still requires federal contractors to file. The Booklet does not address whether President Trump's Executive Order 14173, eliminating Executive Order 11246, changes these reporting obligations.

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