Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
Now that the 2018 EEO-1 Component 1 filing deadline has passed, employers have been anxiously awaiting additional information on the requirements for filing 2017 and 2018 Component 2 compensation data due September 30, 2019.1
On July 2, 2019, following initial notifications to employers of the upcoming Component 2 filing deadline, the EEOC and its contractor, NORC at the University of Chicago, updated the Component 2 website to include both Additional Information and Frequently Asked Questions (FAQs) sections.
Under the Additional Information section, employers can find a sample form, an instruction booklet, a fact sheet, a sample initial Component 2 notification letter sent to employers, and reference documents.
Additionally, under the FAQs section, employers can find answers to questions related to the filing deadline, the filing requirements, the summary compensation and hours worked data to be reported, multi-establishment reporting, the Component 2 online filing system, and confidentiality concerns.
While many of the FAQs are consistent with previous guidance the EEOC provided, an FAQ employers will find particularly helpful is one related to whether an employer must choose the same “workforce snapshot period” for Component 2 data that it chose for Component 1 EEO-1 reporting for 2017 and 2018. The answer is “no,” employers are permitted to choose different workforce snapshot periods for reporting Component 2 data for 2017 and 2018. In other words, there is no requirement that the workforce snapshot periods match for 2017 Component 1 and 2 or 2018 Component 1 and 2.
We will be conducting a complimentary webinar on July 19 to provide additional information to employers working to comply with these new reporting requirements.2 In the meantime, we encourage employers to review the FAQs in detail.
1 See Jim Paretti, EEOC to Require Employers to File 2017, 2018 Compensation Data by September 30, 2019, Littler ASAP (May 2, 2019).
2 Those interested in the webinar can contact the authors for more information.