UPDATE: EEOC Clarifies Change To EEO-1 Reporting For Employees At Client Sites

Jackson Lewis P.C.
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As we recently reported, the instructions for filing current EEO-1 reports includes a change to the reporting requirements for employees working at client sites.

Acknowledging confusion surrounding the instruction, EEOC presented the following today during a webinar held for members of the Industry Liaison Group community:

It has come to the EEOC’s attention that there may be some confusion as to how employers are to report employees working at client sites.  Some employers have been reporting the address of client sites for employees, while other employers have instead been rolling those employees up to a non-client site employer address.  Given this confusion, employers will not be considered “non-compliant” if they have chosen one approach over the other – either reporting by client site or by non-client site employer address. 

The EEOC noted it is currently reviewing how to address client site reporting. We will provide an update when additional clarification or direction is available.

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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