On April 15, 2025, the Equal Employment Opportunity Commission (EEOC) sought approval of its 2024 EEO-1 Component 1 data collection. The EEOC’s new proposed 2024 EEO Component 1 Instruction Booklet (the “Booklet”) changes some reporting obligations for employers. If approved, employers will have from May 20, 2025, to June 24, 2025, to file their reports. Private employers with at least 100 employees must file the EEO-1 report annually. In addition, federal government contractors with 50 employees previously were required to file EEO-1 reports. What is less clear is whether government contractors with less than 100 employees will have to file their EEO-1 report. The EEOC’s proposed Instruction Booklet still requires federal contractors to file. The Booklet does not address whether President Trump’s Executive Order 14173, eliminating Executive Order 11246, changes these reporting obligations.
One major proposed change to the EEO-1 report is the removal of the option for employers to report employees who identify as nonbinary. Employers previously could report nonbinary employees in a separate comment box. If approved, that option would not be available. The instruction booklet does not require employers to collect or report pay data.
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We will monitor whether the 2024 Instruction Booklet is approved. In the meantime, employers should collect data by employee job category, as well as by sex and race/ethnicity, now so they are ready to report in May or June.
