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ARTICLE · 09 MAY 2019

Revised EEO-1 Requirements Take Effect: Employee Pay Data Must Be Submitted To EEOC By September 30

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On April 25, 2019, a federal district court ruled that employers must provide pay data to the Equal Employment Opportunity Commission (EEOC) by September 30, 2019.

United StatesEmployment and HR

On April 25, 2019, a federal district court ruled that employers must provide pay data to the Equal Employment Opportunity Commission (EEOC) by September 30, 2019. This ruling is the latest decision in a years-long battle over whether (and when) employers are required to report pay information based on sex, race, and ethnicity to the EEOC.

The EEOC has long required employers to report data on employees' ethnicity, race, and sex on the annual "Employer Information Report EEO-1" (EEO-1). The EEO-1 requirements apply to all employers with 100 or more employees and federal contractors with 50 or more employees.

In 2016, the Obama administration announced its intention to seek a three-year approval from the Office of Management and Budget (OMB) of a revised EEO-1. The revised EEO-1 would have two components. Component 1 would capture the same information that is currently reported by employers (i.e., data on employees' ethnicity, race, and sex, by job category).

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