In an effort to assist employers, the EEOC has posted guidance and sample forms for the new EEO-1 Component 2 Compensation Data reporting requirements on its website. The new materials provide useful information for employers to comply with the new reporting requirement. As we have previously reported, employers must now report employee pay data and hours worked, by job category, in addition to the usual workforce demographic information. The EEOC informed employers this spring that it will require submission of 2017 and 2018 data by September 30, 2019.

The new materials include a sample Component 2 Form, an 18-page instruction book for filers and a two page Fact Sheet. The EEOC also provides useful links to EEO-1 and NAICS job classification guides. Covered employers should bookmark this webpage, as the EEOC will release an additional “Users Guide” on or after July 15, 2019, when the Component 2 filing period begins. Employers are encouraged to review these materials in advance of the filling period.

Employers should also consult with counsel to ensure that their Component 2 submissions are compliant and work through the numerous issues the new submission requirements raise. We will continue to provide updates on this matter as they become available.