EEO-1 Component 2 Filing System is Now Open

HIGHLIGHTS

Employers must submit 2017 and 2018 EEO-1 “Component 2” data by Sept. 30, 2019.

  • The Component 2 EEO-1 filing system opened on July 15, 2019.
  • 2018 EEO-1 “Component 1” data was due by May 31, 2019.
  • Private employers with 100 or more employees and certain federal contractors must file.

IMPORTANT DATES

July 15, 2019

The EEOC began collecting 2017 and
2018 EEO-1 Component 2 data

September 30, 2019

Deadline to submit 2017 and 2018
EEO-1 Component 2 data

OVERVIEW

The online filing system that employers must use to submit pay and work-hour (“Component 2”) data is now available, the Equal Employment Opportunity Commission (EEOC) announced on July 15, 2019.

Employers subject to EEO-1 reporting requirements must use this new system to submit their Component 2 data from both 2017 and 2018 as part of their 2018 EEO-1 Reports. The deadline for this submission is Sept. 30, 2019. According to the EEOC, each employer’s system login information was sent via U.S. mail and email on July 15, 2019.

ACTION STEPS

Employers subject to EEO-1 reporting should:

  • Begin using the Component 2 EEO-1 online filing system to submit their 2017 and 2018 pay and work hour data; and
  • Ensure that their Component 2 data submissions are complete by Sept. 30, 2019.

Employers subject to EEO-1 Reporting Requirements
With some exceptions, the following entities must use the Component 2 EEO-1 online filing system to submit EEO-1 Component 2 data from both 2017 and 2018 by Sept. 30, 2019:

  • A private employer that has 100 or more employees (with limited exceptions for schools and other organizations);
  • A private employer with between 15 and 99 employees, if it is part of a group of employers that legally constitutes a single enterprise employing 100 or more employees; and
  • A federal contractor that has 50 or more employees and is either a prime contractor or first-tier subcontractor, and has a contract, subcontract or purchase order amounting to $50,000 or more.

These employers were also required to submit 2018 EEO-1 Component 1 data, using the EEOC’s website, by May 31, 2019. The Component 2 EEO-1 online filing system is separate from that website.

Component 2 Filing System

A separate filing system is being used for 2017 and 2018 Component 2 data because the EEOC has contracted with an outside provider to collect this particular information. This is the result of a federal court order issued on March 4, 2019, which requires the EEOC to collect the Component 2 data no later than Sept. 30, 2019.

Although the U.S. Department of Justice has appealed that order, the requirement for employers to file their 2017 and 2018 Component 2 data still applies while the appeal is pending.

More Information and Employer Support

In addition to the online filing system, the EEOC has released an email address (eeoccompdata@norc.org) and toll-free phone number (877-324-6214) that employers may use to obtain additional information or support regarding their Component 2 data submission obligations.

The EEOC also provides answers to Frequently Asked Questions and a list of links to additional materials and information about the Component 2 data submission requirements for employers.