Very Important Time-Sensitive New Requirements for EEO-1 Component 2 Filings

26 July 2019 Legal News: Labor & Employment Publication
Author(s): Jeffrey S. Kopp

Under new EEO-1 reporting requirements, private employers with 100 or more employees are required to submit Component 2 data for the calendar years 2017 and 2018 by September 30, 2019.

The Component 2 EEO-1 survey for 2017 and 2018 submissions is now open, and the portal for filing is: A copy of the online sample can be found here.

The Component 2 report will collect employee counts by pay bands as well as by hours worked. Employers are required to select a pay period between October 1 and December 1 of the reporting year as the “workforce snapshot period.” Compensation and hours worked data will only be reported for full-time and part-time employees who were on the employer’s payroll during the workforce snapshot period. Component 2 requires employers to supply W-2 income data for employees in each of 10 different detailed job categories. That data is then categorized by employee compensation into 12 different annual pay amounts organized by bands ranging from about $19,000 to more than $208,000.

It is highly recommended that companies perform a self-audit of payroll data before it is submitted, as the EEOC could ultimately use this data to raise claims of pay discrimination based on gender and ethnicity. Our firm can assist your company by reviewing the compensation data and identifying potential disparities within each job category (EEO Code) relative to race and gender.

In order to conduct this review, we would need to receive the following data:

  • employee name
  • employee race
  • employee gender
  • date of hire
  • job title
  • EEO Code for job title
  • number of hours worked per week
  • W-2 income data for 2018 (This same data is needed for 2017.)

Please let us know if we can be of assistance to you in this process or with a review. You can reach out to your regular Foley contact or to Jeff Kopp ( or Susan Coleman ( to initiate any requests for assistance.

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