[With special thanks to our summer associate Whitney Chukwurah for her contribution to this post.]
All private employers with 100 or more employees in the US and certain federal contractors with 50 or more employees in the US must report data on race/ethnicity and gender across job categories in their annual EEO-1 filings. As previously reported (HERE), in 2016, under the Obama Administration, the Equal Employment Opportunity Commission revised the EEO-1 form to require certain employers to report W-2 wage information and total hours worked (referred to as Component 2 Data) for all employees by race, ethnicity and sex within 12 EEOC created pay bands.
The implementation of the revised EEO-1 form has been subject to litigation; however, covered employers now have until September 30, 2019 to provide EEOC with pay data.
Continue Reading New EEOC Guidance On Submitting Component 2 Pay Data