I posted earlier this morning about the D.C. Circuit Court’s order approving the EEOC’s request to set September 30, 2019 as the deadline for employers to submit EEO-1 Component 2 data. The Court’s order requires the EEOC to collect Component 2 pay data for calendar years 2017 and 2018. However, the Court gave the EEOC the option to collect Component 2 data for 2019 instead of 2017, and set a deadline of May 3, 2019 for the EEOC to make its decision.
If the EEOC exercises the option to collect pay data for 2019 instead of 2017, the 2019 pay data must be reported during the 2020 EEO-1 reporting period.
The Court also gave the EEOC an April 29, 2019 deadline to issue a statement on its website announcing to EEO-1 filers that they should prepare to submit Component 2 data no later than September 30, 2019, and to alert filers if it has decided by April 29, 2019 whether to collect 2017 or 2019 data.
We will continue to post updates on developments related to this subject. In the interim, employers with 100+ employees need to begin collecting Component 2 pay data to be able to comply with the September 30th deadline.
The Court’s order is here: Order [Dkt 71]