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Employers Must Submit Two Years of EEO-1 Component-2 Data by Sept. 30, 2019

The Equal Employment Opportunity Commission chose a deadline based on a decision from a federal district court that will require employers to submit two year's worth of employee pay data, known as Component-2, on their EEO-1 by Sept. 30, 2019.
Two women preparing to submit pay data required by Equal Employment Opportunity Commission.

Covered employers will be required to report additional data to the Equal Employment Opportunity Commission, following a recent decision by the U.S. District Court for the District of Columbia.

The new data – referred to as Component-2 data – includes employee pay data, hours and wages, sorted by race, ethnicity, and sex within 12 pay bands. The deadline for submitting this required data for 2017 and 2018 is Sept. 30, 2019.

Remember, Component-1 data is due May 31, 2019. The portal currently is open to submit Component-1 data and will open for Component-2 data in mid-July 15.


Under the previous administration, the EEOC added Component-2 data to the EEO-1 Report in addition to the demographic data already being collected.

“Collecting data is a critical step in delivering on the promise of equal pay,” U.S. Secretary of Labor Thomas E. Perez was quoted as saying in a press release. “Better data will not only help enforcement agencies do their work, but it helps employers to evaluate their own pay practices to prevent pay discrimination.”

In 2017, the Office of Management and Budget (OMB) stayed the requirement to collect Component-2 data for the EEO-1 Report.

The recent federal district court decision in National Women’s Law Center, et al., v. Office of Management and Budget, et al., settled a lawsuit that claimed the OMB exceeded its statutory authority in reviewing and staying the collection of pay data as part of EEO-1 reporting.

What employers must know

Covered employers are required to report information, and based on the court decision have two deadlines – May 31, 2019 for 2018 Component-1 data and Sept. 30, 2019 for 2017 and 2018 Component-2 data.

Employers handling Component-2 data must report the income provided in Box 1 of the employee’s Form W-2, plus report the total hours worked by employees in each pay band.

What’s next

Covered employees will need to prepare to submit Component-2 data and should watch for the EEOC to post additional guidance and instructions on their website.

Paychex will update as additional information becomes available.

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Jennifer Swayze is a compliance analyst with a focus on employment law at Paychex, Inc., a leading provider of integrated solutions for payroll, HR, retirement, and insurance services.

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* This content is for educational purposes only, is not intended to provide specific legal advice, and should not be used as a substitute for the legal advice of a qualified attorney or other professional. The information may not reflect the most current legal developments, may be changed without notice and is not guaranteed to be complete, correct, or up-to-date.

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