EEOC Proposes To Collect New Data On Pay

Background: As part of the Obama Administration's initiative to advance equal pay policies, on January 29, 2016, the Equal Employment Opportunity Commission ("EEOC") released a proposal that would expand the information many private entities must report to the EEOC. Specifically, the proposed revision would require all employers with 100 or more employees (both private industry and federal contractors) to collect and report data on pay and hours-worked on their annual employer information reports (i.e. EEO-1 forms). Employers have previously reported to the EEOC the number of their employees by sex, race, ethnicity, and job category. However, it should be noted that the proposal is not a rulemaking and is a proposed revision of an existing EEOC information collection.