The EEOC’s September 30th deadline for all covered employers to submit pay data for 2017 and 2018 wage data is right around the corner. While some employers may have implemented data collection tools intended to meet this requirement when a revised EEO-1 report was released in October 2016, others delayed implementation after use of the revised EEO-1 report was halted and litigation ensued over the revised EEO-1 report. A court order issued earlier this year reinstituted the filing requirement for all covered employers.
Covered employers are those private employers who had 100 or more employees in a self-selected “snapshot period” between October 1st and December 31st of 2017 and who had 100 or more employees in a self-selected “snapshot period” between October 1st and December 31st of 2018. The self-selected “snapshot period” can be different periods for each year and can also be a different period than what was selected for the “snapshot period” for the EEO-1 Component 1 report (employee counts by race and ethnicity groups by gender and job category). Notably, federal contractors and subcontractors with 50 to 99 employees who are required to file annually EEO-1 Component 1 data are not required to file the Component 2 wage data.