2022 EEO-1 Reporting – Hang Tight For Now

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Under Title VII of the Civil Rights Act, private sector employers with 100 or more employees and certain federal contractors with 50 or more employees are required to provide demographic information of their workforces—otherwise known as EEO-1 Component 1 reporting. This includes data such as sex, race, ethnicity, and job categories.

The 2022 reporting period has been delayed. It is currently scheduled to open in the fall of 2023—with no date set in stone.

The EEOC is in the process of doing a three-year renewal of EEO-1 Component 1 reporting with the Office of Management and Budget (“OMB”) which is required by the Paperwork Reduction Act. While the Biden administration has expressed support for collecting compensation data with the EEO-1 report, EEOC has made clear on the EEO-1 Component 1 page that it is not making changes to the EEO-1 Component 1 data collection categories.  Rather, EEOC is seeking to update how the data is collected from employers and to reduce the burden of this collection on employers, including no longer requiring “multi-establishment filers” to submit separate reports based on the size of establishments.

While EEOC has not announced a deadline for 2022 EEO-1 Component 1 reporting, required employers and contractors should continue ensuring they are collecting the necessary demographic data to be ready for the deadline. Once a deadline is determined, it will be posted on the EEO-1 Component 1 page, and employers should note that the actual reporting process may look different (and may be less burdensome) if the OMB approves changes to the data collection methods.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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