Federal Court Orders EEOC to Collect EEO-1 “Component 2” Pay Data by September 30, 2019

Thursday, April 25, 2019

Not unexpectedly, the federal district court for the District of Columbia today ordered the Equal Employment Opportunity Commission (EEOC) to collect “component 2” pay and hours-worked data for Calendar Year 2018 from employers on a revised EEO-1 Report by September 30, 2019, and ordered the EEOC to notify employers of this mandate by next Monday, April 29.

The court also ruled that employers will be required to submit a second year of pay and hours-worked data – either for Calendar Year 2017, to be submitted by September 30, 2019, or for calendar year 2019, to be submitted in 2020 - and has given the EEOC until May 3, 2019, to determine which year of additional data to collect.

We will have additional information after the EEOC publishes its mandate on Monday, and we will issue a memorandum shortly thereafter providing details. CWC members are cautioned that there still could be additional developments in this matter, for example, the government could still appeal the court’s ruling, and we will advise you immediately if something occurs.

In the meantime, if you have any questions, please feel free to contact one of our compliance policy experts at 202-629-5650 or info@cwc.org.

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