Colin Barnacle is a Senior Counsel in Holland &
Knight's
Denver office
On July 13, 2016, the EEOC unveiled a revised version of its
proposal to expand the collection of compensation data from certain
employers. The revised proposal applies to employers including
federal contractors and employers with more than 100 workers. The
update comes with a fresh 30-day comment period, ending August 15,
2016. The revised proposal retains the majority of the provisions
of the original version, making only a handful of concessions in
response to commenter suggestion. Specifically, the revised
proposal changes the due date for the EEO-1 survey from September
30, 2017 to March 31, 2018 to better coordinate with the date range
covered by existing W-2 reports. This change extends the deadline
and eliminates the requirement for employers to report W-2 wages
over two partial calendar years. Nevertheless, the revised proposal
still poses a variety of problems for employers,
