Executive Summary: On March 4,
2019, the U.S. District Court for the District of Columbia ruled to
reinstate Obama-era revisions to the pay data reporting
requirements established by the Equal Employment Opportunity
Commission (EEOC), which effectively expand employers’ EEO-1
reporting requirements and obligate them to submit detailed
employee pay data annually to the EEOC. This ruling will have
important consequences for employers, and has raised understandable
uncertainty and concern among the business
community.
Background: The EEOC has long required
private employers covered by Title VII of the Civil Rights Act with
100 or more employees and federal contractors with 50 or more
employees to submit annual reports, known as EEO-1 submissions,
which break down the number of workers employed with the company
based on gender, race, and ethnicity. On September 29, 2016,
the EEOC revised its pay data reporting requirements to expand the
obligations placed on
