EEOC Sets Sept. 30, 2019 as the New Deadline for EEO-1 Pay Data Reporting

April 4, 2019 Advisory

In response to a federal district court’s recent order vacating a stay of EEO-1 pay-data reporting requirements that the Office of Management and Budget (OMB) implemented in August 2017, the Equal Employment Opportunity Commission (EEOC) has announced Sept. 30, 2019, will be the new deadline for the collection of EEO-1 pay data from employers. That data includes employees' W-2 earnings and hours worked in 12 pay bands for the 10 EEO-1 job categories (“i.e., Component 2 data”).

In setting the Sept. 30 deadline, the EEOC has acknowledged that the agency does not currently have the ability to process Component 2 data and that it will have to utilize a contractor to handle the collection of employee pay data in order to satisfy the agency’s own newly established Sept. 30 deadline. The EEOC estimates the cost of utilizing a contractor for this data processing work to be in excess of $3 million.

Private sector employers with 100+ employees and covered federal government contractors are required to complete the EEO-1 report annually. Traditionally, EEO-1 reports have provided the federal government with data on the race and gender of employees in 10 EEO-1 job categories, ranging from Executive and Senior Level Officials/Managers to Service Workers (i.e., “Component 1 data”). The OMB revised the EEO-1 form in 2016 to require submission of Component 2 data, including aggregate wage and hours worked data for employees, organized by race and gender, in the 12 pay bands. Compliance with this new data collection and reporting requirement was expected to create significant burdens for the business community, and in response to outcry over those burdens, the OMB stayed enforcement of the Component 2 requirements in August 2017. Last month, a federal judge lifted that stay, finding that the OMB failed to assert a proper justification to stay a measure it previously approved.

EEO-1 Component 1 data must generally be submitted by March 31 following the reporting year; however, the EEOC has extended the deadline for filing 2018 EEO-1 reports to May 31, 2019, due to the government shutdown.


Contact Us
  • Worldwide
  • Boston, MA
  • Chicago, IL
  • Denver, CO
  • Dublin, Ireland
  • Edwardsville, IL
  • Jefferson City, MO
  • Kansas City, MO
  • Las Vegas, NV
  • London, England
  • Miami, FL
  • New York, NY
  • Orange County, CA
  • Philadelphia, PA
  • Princeton, NJ
  • Salt Lake City, UT
  • St. Louis, MO
  • Washington, D.C.
  • Wilmington, DE
abstract image of world map
Boston, MA
800 Boylston St.
30th Floor
Boston, MA 02199
Google Maps
Boston, Massachusetts
Chicago, IL
100 North Riverside Plaza
Suite 1500
Chicago, IL 60606-1520
Google Maps
Chicago, Illinois
Denver, CO
4643 S. Ulster St.
Suite 800
Denver, CO 80237
Google Maps
Denver, Colorado
Dublin, Ireland
Fitzwilliam Hall, Fitzwilliam Place
Dublin 2, Ireland
Google Maps
Edwardsville, IL
115 N. Second St.
Edwardsville, IL 62025
Google Maps
Edwardsville, Illinois
Jefferson City, MO
101 E. High St.
First Floor
Jefferson City, MO 65101
Google Maps
Jefferson City, Missouri
Kansas City, MO
2345 Grand Blvd.
Suite 1500
Kansas City, MO 64108
Google Maps
Kansas City, Missouri
Las Vegas, NV
7160 Rafael Rivera Way
Suite 320
Las Vegas, NV 89113
Google Maps
Las Vegas, Nevada
London, England
Royal College of Surgeons of England
38-43 Lincoln’s Inn Fields
London, WC2A 3PE
Google Maps
Miami, FL
355 Alhambra Circle
Suite 1200
Coral Gables, FL 33134
Google Maps
Photo of Miami, Florida
New York, NY
7 Times Square, 44th Floor
New York, NY 10036
Google Maps
New York City skyline
Orange County, CA
19800 MacArthur Boulevard
Suite 300
Irvine, CA 92612
Google Maps
Philadelphia, PA
2005 Market Street
29th Floor, One Commerce Square
Philadelphia, PA 19103
Google Maps
Philadelphia, Pennsylvania
Princeton, NJ
100 Overlook Center
Second Floor
Princeton, NJ 08540
Google Maps
Princeton, New Jersey
Salt Lake City, UT
222 South Main St.
Suite 1830
Salt Lake City, UT 84101
Google Maps
Salt Lake City, Utah
St. Louis, MO
7700 Forsyth Blvd.
Suite 1800
St. Louis, MO 63105
Google Maps
St. Louis, Missouri
Washington, D.C.
1717 Pennsylvania Avenue NW
Suite 400
Washington, DC 20006
Google Maps
Photo of Washington, D.C. with the Capitol in the foreground and Washington Monument in the background.
Wilmington, DE
1007 North Market Street
Wilmington, DE 19801
Google Maps
Wilmington, Delaware