The Equal Employment Opportunity Commission (EEOC) has announced that covered employers must submit Component 2 data (hours worked and pay data by race, ethnicity, and sex) for 2017 and 2018 by September 30, 2019. The deadline for submitting Component 1 data (the number of employees by job category, race, sex, and ethnicity) remains unchanged.

Covered employers (businesses with 100 or more employees and federal contractors with 50 or more employees) should begin preparing to report this data by the September 30th deadline. While it is very likely that there will be continued legal challenges, it is best to begin compiling the necessary data (if you haven’t already) by the September 30, 2019. It’s going to be a significant undertaking whether you begin now or wait.

In addition to compiling your W-2 pay data and hours worked, covered employers should review their current pay systems for any areas where there is a pay disparity. Some disparities may have legitimate and non-discriminatory explanation. Those that do not should be addressed and resolved now before they come under government scrutiny.

The EEOC has advised that it will offer training and provide detailed information about employers’ reporting obligations well in advance of the September 30 deadline. Employers should expect this information sometime between now and mid-July when the collection portal opens.

Many employers have already begun the process of compiling the necessary data to comply with the September 30th deadline. Many began as soon as the reporting requirement was reinstated in early March as we advised.

Nevada Association of Employers (NAE) will continue to monitor the latest developments on the EEO-1 report to ensure you stay informed and in compliance.