As we most recently reported
here and
here, as of September 30, 2019, employers with 100 or more
employees (and federal contractors with 50 or more employees) were
required to report to the federal government pay data for 2017 and
2018 for their workforce (known as "Component 2" data),
broken down by race/ethnicity, sex, and job category. However,
consistent with its current practice regarding submission of
Component 1 data – which consists of a listing of
employees' job category, sex, race, and ethnicity – the
EEOC has agreed to continue collecting Component 2 data for a
six-week period after the September 30, 2019 deadline, ending on
November 11, 2019.
The pay data collection process has been the subject of ongoing
litigation in the U.S. District Court for the District of Columbia.
In April 2019, it issued an order approving the September 30, 2019
deadline and requiring the EEOC to file status reports every 21
days explaining the steps the agency was taking to
