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EEO-1 pay data reporting revived: Are you ready to take action?

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On March 4, a federal judge ruled that the Trump administration’s freeze on the pay disclosures portion of the EEO-1 passed by the Obama administration in 2016 was not properly justified. This comes only a week after the Equal Employment Opportunity Commission (EEOC) announced an extension to its EEO-1 reporting deadline from March 31, 2019 to May 31, 2019.

Employers should be aware that the ruling could take immediate effect and require them to report data on W-2 wages and hours worked for all employees who were part of their 2018 workforce snapshot.

The EEO-1 survey is required for all private employers with 100 or more employees and federal government contractors or first-tier subcontractors with both 50 or more employees and $50,000 in government contracts to electronically submit their report. The EEO-1 report captures employees’ race/ethnicity and gender information grouped by job categories.

In preparation, we recommend employers revisit the preparations made in 2017 to file the pay-data component of the revised EEO-1 report. Look for updates from HKP on this topic as well as other important compliance regulations.