EEOC’s Revised EEO-1 Report Requirements – Wage Parity Reform
In January 2016, the U.S. Equal Employment Opportunity Commission (EEOC) proposed revising the Employer Information Report EEO-1 (otherwise known as the EEO-1 Report) to require all employers with 100 or more employees, including federal contractors, to also provide a summary of data on wages paid to their employees, categorized by gender, race and ethnicity beginning with the September 2017 report. The January 2016 proposal involved reporting this information across 10 job categories and by 12 pay bands. Based upon comments submitted on the EEOC’s proposed changes, on July 13, 2016, the EEOC amended its proposed revisions to the EEO-1 Report.
As revised, the EEOC has proposed a calendar year reporting schedule and moved the 2017 EEO-1 reporting due date from September 30, 2107 to March 31, 2018. This change will allow employers to use annual W-2 wage data, already compiled for tax purposes, which would reduce costs for employers to compile the reportable pay data, and would provide a full 18 months for the transition to the new reporting requirements. Employers would provide this data through an online form, a sample of which can be found here.
The revised proposal will be subject to a 30-day comment period that ends on August 15, 2016. As the EEOC may not issue a final proposal until this winter and the new deadline a few months to follow, it may be advisable for covered employers to review and become familiar with the sample EEO-1 form to anticipate the pay data that may need to be gathered.