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Important EEO-1 Component 2 Deadline Approaching This Month

An important deadline approaches for those employers required to file the EEO-1 survey – which generally includes employers with at least 100 employees. In April 2019, a federal court ordered the Equal Employment Opportunity Commission (EEOC) to collect “Component 2” data for the EEO-1, with that data due from employers on September 30, 2019. Component 2 reports data regarding summary compensation and hours worked for purposes of tracking pay equity across the demographic reporting categories.  A reporting employer draws this data from a single, employer-selected pay period between October 1 and December 31 of the reporting year.

The chart below summarizes recent, upcoming, and anticipated deadlines and information for the EEO-1’s Components 1 and 2.

EEO-1 Component

Due Date


Pay Period

Component 1

2018: May 31, 2019


2019: March 31, 2020

Gender, race/ethnicity, & job category for all employees.

Any pay period between Oct. 1 and Dec. 31, for both 2017 and 2018.

Component 2

2017 & 2018: September 30, 2019


2019: March 31, 2020 (starting next year, Components 1 and 2 will likely be due on the same date)

W-2 wage information & total hours worked for all employees by gender, race/ethnicity, job category, and pay.

Any pay period between Oct. 1 and Dec. 31, for both 2017 and 2018. Does not have to be the same pay period as used for Component 1.

Employers must submit the Component 2 data electronically through the EEOC’s Component 2 EEO-1 Online Filing System, or by submitting a data file to the EEOC.  An acquiring or newly merged company might also be responsible for reporting data of newly-acquired employees for whom they did not previously report and so should solicit legal counsel to confirm its Component 2 reporting duties for such employees. Both full and part-time employees’ data are included in EEO-1 reporting.

The EEOC has issued guidance to help employers submit the data, including a sample form and an instruction booklet. Employers should consult with counsel to ensure compliance with these new data submission requirements.

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