Update – Employers Are Required To Submit Pay Data by September 30, 2019

As we previously reported here last month, a federal court reinstated the requirement to include pay data in the EEO-1 Report.  The court required the Equal Employment Opportunity Commission (EEOC) to indicate by April 3, 2019 how it intended to implement this requirement for the current 2018 EEO-1 Report, which employers had already begun submitting. 

Yesterday, the EEOC announced that employers are required to include pay data in the 2018 EEO-1 Report by September 30, 2019.  This new requirement appears in Component 2 of the Report.  To complete Component 2, employers must submit employee pay data from “one single payroll period” of the employer’s choosing between October 1 and December 31, 2018.

If you have any questions about this new requirement, please contact one of Honigman’s Labor and Employment attorneys.