Update: Per an April 2019 court order, the deadline for submitting the Component 2 pay data to the EEOC will be September 30, 2019. It is expected that the EEOC will publish guidance during the summer regarding the submission of this data. In early May, 2019, the EEOC announced that EEO-1 filers will have to submit both 2017 and 2018 Component 2 pay data by September 30, 2019. That is two years of data instead of one. EEO-1 filers are advised to start collecting both years’ pay data to prepare for the September deadline.
At the end of March, we posted an article concerning the reinstated Equal Employment Opportunity Commission (EEOC) pay data reporting requirements.
On March 15, 2019, a federal court issued an order lifting the stay on the EEOC’s pay data reporting requirement. Based on the terms of the court order, the deadline for employers to submit their 2018 EEO-1 data, referred to as “Component 1,” has been extended to May 31, 2019. The court ruled that the EEOC had until April 3, 2019 to inform employers whether they will be required to submit pay data information (“Component 2”) with their 2018 EEO-1 form, or if pay data reporting will begin at a later date.
The EEOC has since concluded in its report to the court that the deadline for collecting pay data is extended to September 30, 2019. Employers may have been granted a temporary reprieve on pay data submission, but still need to submit their 2018 “Component 1” EEO-1 data by May 31, 2019, including information such as gender, race and job categories (see our previous article on EEO-1 reporting, or view the EEOC's frequently asked questions).
It is possible the EEOC could further delay the pay data deadline, but based on its report to the court, the EEOC is forging ahead with the September 30, 2019 deadline in place. Consequently, employers should begin compiling their pay data information now, in anticipation of the September 30, 2019 deadline.
Contact us for more information. Clients with access can contact our HR Hotline with pay data reporting questions.
As a Client Technology Specialist, Karen helps our clients navigate the numerous technology solutions available in the marketplace to assist them in meeting their organization’s strategic goals.
As a Client Technology Specialist, Karen helps our clients navigate the numerous technology solutions available in the marketplace to assist them in meeting their organization’s strategic goals. Karen also serves as a technical expert, and project manager for Associated Financial Group’s proprietary client technology solutions. Her duties include assisting in the creation and innovation of our technology solutions and supporting our clients and colleagues in utilizing these solutions.
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