On April 4, 2019 a U.S. District Court Judge in the District of Columbia surprised employment law officials and federal contractors by reinstating Component 2 Compensation Data for most US employers. This means employers (including federal contractors) with 100 or more employees in 2018 filing EEO-1 Reports, must now collect and file aggregated employee pay information and total hours worked by September 30, 2019!
EEOC’s website notice provides general information now; however, Officials state more information is coming to address other questions, such as, format of the revised EEO-1 Report, filing procedures, etc.
In the meantime, employers filing EEO-1s in 2018 should begin collecting and reviewing the Compensation 2 Data and hours-worked information they will use for Component 2 reporting.
EEOC expects to begin data collection of EEO-1 Component 2 data for calendar year 2018 in mid-July 2019 and will notify filers of the precise date the survey will open as soon as it is available.
As a result of the Court vacating OMB’s stay of Component 2, EEOC has stated it will also collect Component 2 data for either calendar year 2017 or calendar year 2019 and will post an additional notice by May 3, 2019, announcing its decision.