The bad news is that your company may still be recovering from trying to compile and organize all of the EEO-1 Component 2 pay data for submission by September 30, 2019. The good news, however, is that the EEOC has announced that it will no longer collect Component 2 pay data in the future. (Everyone can let out a collective sigh of relief now!) To the extent they haven’t already done so, companies are still required to submit Component 2 pay data for years 2017 and 2018 this year, but they will not be required to do so on an ongoing basis.
The EEOC recognized that the burden imposed on employers to collect the pay and hours information broken down by job category, race, sex and ethnicity outweighs the “unproven utility” of the data. But the typical EEO-1 submission isn’t going anywhere. The EEOC has been collecting employee data by job category, ethnicity, race, and sex (Component 1 data) annually since 1966. The EEOC views Component 1 data as a valuable resource for the analysis of industries and regions and for investigators in assessing allegations of discrimination.
Contact your Baker McKenzie lawyer to assist with questions about EEO-1 reporting requirements.