Department of Justice to Appeal Court Decision Requiring EEO-1 Pay Data Collection

Monday, May 6, 2019

Late Friday evening, as we previously indicated might happen, the U.S. Department of Justice filed a  Notice of its intention to appeal a federal court order in National Women's Law Center v. OMB reinstating the requirement for employers to report pay and hours-worked data (Component 2 data) on their EEO-1 Reports.

It is too soon to say precisely what the practical impact will be of the government’s decision to file its Notice of Appeal. It should be emphasized, however, that the filing of the Notice does not relieve contractors of their obligation to report Component 2 data for Calendar Years 2017 and 2018 by September 30, 2019, in conformance with the district court’s decision.

CWC will provide further details in a memo to be published later this week, and we will continue to keep you posted as additional details become available. In the meantime, if you have any questions, please feel free to contact one of our compliance policy experts at 202-629-5650 or


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