Seyfarth Synopsis: On July 14, 2016, the
EEOC released revisions to the EEO-1 proposed rule that will
require many employers to annually report pay data if approved in
its current form. While the EEOC clarified certain provisions
and modified others, key provisions of the revised proposed rule
remain largely unchanged. The changes do not address the most
significant problems with the pay data collection tool and, in
particular, the usefulness of the data in meaningfully identifying
discriminatory pay disparities.
In February, the Equal Employment Opportunity Commission (EEOC)
announced a major revision to the Employer Information Report
(EEO-1) which, if approved by the Office of Management and Budget
(OMB), will require that all employers with more than 100 employees
submit compensation data to the EEOC beginning in 2017. For
more information on the EEOC's initial proposal to collect pay
data, see our earlier alerts
here,
here, and
here.
