EEO-1 Pay Data Deadline Presumably Extended

Published Friday, April 5, 2019

As we previously alerted you, on March 04, 2019, a U.S. Federal District Court reinstated the 2016 EEO-1 summary pay data reporting requirements. With this ruling, employers who have 100 or more employees and most federal contractors with 50 or more employees are now required to submit pay data in addition to race, ethnicity and sex data through an EEO-1 Report annually.

The EEO-1 Report was opened on March 18, 2019, and the deadline for submission for all data was presumably May 31, 2019. However, on April 3, 2019, the EEOC submitted court documents stating that it could complete EEO-1 pay data collection, contingent on the use of a third party contractor, by September 30, 2019. The court has yet to rule on this proposed plan.

It is worth noting that the EEOC’s proposed plan does not change the deadline for race, ethnicity and sex data collections. This deadline is still May 31, 2019. This proposal does, however, change the proposed deadline for pay data. While the EEOC’s proposal has yet to be ruled on, September 30, 2019 is presumably the earliest that pay data collection will be due.

Cascade will continue to monitor and update you on this evolving EEO-1 story. If you have any questions, please let us know!

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