Employers with more than 100 employees have long complied with
the requirement of the Equal Employment Opportunity Commission
(EEOC) to annually report the number of their employees by gender,
race/ethnicity and job category on the EEO-1 Form. In February
2016, the EEOC announced its intention to expand the data it
collects to include pay and other data, commonly known as
"Component 2" data. Employers breathed a collective sigh
of relief in September 2016 when the Office of Management and
Budget (OMB) stayed the implementation of Component 2 data
collection. After a recent federal court ruling, that data is now
due to the EEOC by September 30.
Earlier this year, Judge Tanya S. Chutkan of the U.S. District
Court for the District of Columbia lifted the OMB's stay and
ordered the EEOC to collect two years of EEO-1 Component 2 data
from covered employers (those with more than 100 employees). The
two years had to include such data from 2018 and, at the EEOC's
discretion,