2019 And 2020 EEO-1 Component 1 Reports Due

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On April 26, 2021, the U.S. Equal Employment Opportunity Commission launched its annual EEO-1 data collection process. The COVID-19 pandemic delayed EEO-1 filing last year. As a result, covered employers now must file both their 2019 and 2020 EEO-1 Component 1 Reports by July 19, 2021.

What Is the EEO-1 Component 1 Report?

U.S. employers with at least 100 employees and some smaller companies with federal government contracts must file demographic data each year. The EEO-1 Component 1 Report identifies the number of employees by job categories and demographic characteristics.

The EEO-1 job categories are:

  • Executive/Senior Level Officials and Managers
  • First/Mid-Level Officials and Managers
  • Professionals
  • Technicians
  • Sales Workers
  • Administrative Support Workers
  • Craft Workers
  • Operatives
  • Laborers and Helpers
  • Service Workers

Within these job categories, employers must provide the number of employees based on sex and race/ethnicity from among these options:

  • Hispanic or Latino
  • White
  • Black or African American
  • Native Hawaiian or Pacific Islander
  • Asian
  • Native American or Alaska Native
  • Two or more races

EEO-1 Component 2 Pay Data Collection

In February 2016, the EEOC modified the Form EEO-1 to include wage and hours data beginning March 31, 2018. Following litigation, the EEOC retroactively collected this “Component 2” data for the years 2017 and 2018. The EEOC anticipates completing an analysis of that data by the end of 2021. It remains to be seen whether, or at least when and how, the EEOC will pursue collection of compensation data again in the future.

Filing FAQs

The unusual year resulting from the coronavirus pandemic has raised some new concerns among EEO-1 filers.

How do we account for employees working at home?

Remote workers must be included on the EEO-1 Component 1 Report for the business location to which they report. The employees’ home address should not be reported as a company location.

What if we only qualified for either 2019 or 2020 filing?

Employers should only file for the year(s) in which they had enough employees and otherwise qualified. According to the EEOC, companies who need to file both 2019 and 2020 EEO-1 Component 1 Reports must file the 2019 report first and then the 2020 report.

Companies that merged, spun off, or dissolved during the timeframe might need to file as separate entities for the two years.

Click here to go to the EEOC’s Data Collection portal.

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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