Based on an April 25, 2019, ruling by the U.S. District Court for the District of Columbia, employers who submit an EEO-1 Report must also submit the 2018 Component 2 pay data by September 30, 2019. The Equal Employment Opportunity Commission (EEOC) is expected to update its website by Monday, April 29, 2019, on the Component 2 pay data requirements. It basically requires employers to report pay data by job category, pay band, gender, race and ethnicity. Employers will also have to submit a second year of pay data, but we don’t know yet whether that will be for 2017 or 2019. If the EEOC requires 2017 pay data, then it will be due by September 30. If the EEOC requires 2019 pay data, it will not be due until 2020. The EEOC must notify the court by May 3, 2019, regarding the second year of pay data that will be required.
The deadline to file the EEO-1 report with Component 1 data (race, gender and ethnicity) remains unchanged. It is still due May 31, 2019.