The 2024 EEO-1 Component 1 data collection window opened on May 20, 2025, and the deadline to file the 2024 EEO-1 Component 1 report is June 24, 2025. Filers should note that the collection window is shorter this year, and that beginning this year, all communications sent to filers will be electronic. Updates about the 2024 EEO-1 Component 1 data collection are posted on the EEOC’s dedicated EEO-1 Component 1 website here.
The EEO-1 Component 1 report is a mandatory annual data collection that requires all private sector employers with 100 or more employees, and federal contractors with 50 or more employees meeting certain criteria, to submit workforce demographic data to the EEOC, reporting the number of individuals they employ by job category and by sex and race or ethnicity.
Consistent with the Trump Administration’s Executive Order on gender ideology (Executive Order 14168, issued on January 20, 2025), which mandates recognizing male and female as the only two sexes, the EEOC eliminated the option to include nonbinary employees in EEO-1 reports this year. The updated 2024 EEO-1 Component 1 Data Collection Instruction Booklet states: “The EEO-1 Component 1 data collection provides only binary options (i.e., male or female) for reporting employee counts by sex, job category, and race or ethnicity.”
On May 20, 2025, EEOC Acting Chair Andrea Lucas issued a message regarding the 2024 EEO-1 Component 1 Data Collection, flagging a few key points for filers.
First, Acting Chair Lucas reminded filers of their “obligations under Title VII not to take any employment actions based on, or motivated in whole or in part by, an employee’s race, sex, or other protected characteristics,” and that companies and organizations may not use information about their employees’ race/ethnicity or sex to facilitate unlawful employment discrimination based on race, sex, or other protected characteristics in violation of Title VII. Lucas emphasized that “Title VII’s protections apply equally to all workers, regardless of their race or sex,” that “there is no ‘diversity’ exception to Title VII’s requirements,” citing to the EEOC’s recently released technical assistance document titled “What You Should Know About DEI-Related Discrimination at Work.”
Second, Acting Chair Lucas addressed the Trump Administration’s Executive Order issued on April 23, 2025 titled “Restoring Equality of Opportunity and Meritocracy,” which directs all agencies, including the EEOC, to deprioritize “disparate impact” enforcement. Lucas acknowledged that “the EEOC is an executive branch agency, not an independent agency,” the EEOC “will fully and robustly comply with this and all Executive Orders,” and that under Lucas’s leadership, “the EEOC will prioritize remedying intentional discrimination claims.” Lucas again reminded filers that they “must not use the information collected and reported in your organization’s EEO-1 Component 1 report to justify treating employees differently based on their race, sex, or other protected characteristic.”
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