impactAlert: EEOC Announces Employers Must Report Employee Pay Data by Sep. 30, 2019

The US Equal Employment Opportunity Commission (EEOC) has announced all employers that file the EEO-1 form must also now submit employee pay data by September 30, 2019 as part of the annual EEO-1 filing process.

Key information: employers must prepare pay data (known as Component 2 data) comprising total W-2 wages and total hours worked for each employee for the 2017 and 2018 calendar years. The EEOC’s mandate is to use this data to identify pay disparities based on gender.

The EEOC plans to begin collecting EEO-1 Component 2 data in mid-July 2019. (The EEOC will notify all EEO-1 filers of the precise date the survey will open this July as soon as it is available.)

In addition, employers must still complete and file, by May 31, 2019, the standard EEO-1 form – the EEOC’s demographic survey, which compiles Component 1 data, that categorizes employees by race or ethnicity, gender and job category.

The EEOC’s pay data collection announcement stems from a recent decision by the US District Court for the District of Columbia wherein the court reversed the US Office of Management and Budget’s move in 2017 to cancel the mandate as developed in the previous administration.

Read more about the EEOC’s new pay data collection policy.

impactAction: If you have questions or need assistance with any aspect of EEOC compliance, contact us at or 443-741-3900.