EEO-1 Component 1 Deadline Approaching
EEO-1 Component 1 Data due June 4, 2024
The Equal Employment Opportunity Commission (EEOC) requires certain employers to report information regarding their workforce’s demographics. This is done on an annual basis on an EEO-1 form. This reporting requirement applies to employers who meet the following criteria:
- Private employers with 100 or more employees, or
- Private employers with less than 100 employees but are part of a single enterprise with a total of 100 or more employees, or
- Private employers with federal contracts and 50 or more employees.
The requirement does not apply to public sector employers, Native American tribes or tax-exempt private membership clubs.
Required Data
The federal EEOC breaks its data collection efforts into different “components”. Private employers need to complete reporting under Component 1. Component 1 consists of:
- The number of employees sorted by 10 job categories, race/ethnicity and gender. Reporting Component 1 data is required annually and is due by June, 4, 2024.
In years past, there was second part to EEO-1 reporting known as Component 2 which required additional reporting of employee compensation. Data collection under Component 2 has not been required since the 2017 and 2018 calendar years.
Threshold
If an employer needs to determine if they meet the 100 employee threshold for 2023, an employer should count the number of employees during a “workforce snapshot period” for 2023. The “workforce snapshot period” is an employer-selected pay period between October 1 and December 31 of the reporting year.
If an employer meets the 100 employee threshold at any time during the 4th quarter (October 1 through December 31), then the employer may not select a workforce snapshot period where it falls below the 100 employee threshold. Full- and part-time employees employed during the workforce snapshot period must have their demographic information reported to the EEOC.
Filing
The EEOC will begin accepting EEO-1 Component 1 reporting on April 30, 2024. Employers will complete this reporting through the EEO-1 Component 1 Online Filing System which is accessible here. Information is submitted by uploading a data file or manually entering the required data.
The EEOC publishes instructions which you may find helpful as you work towards completing your EEO-1 Component 1 reporting. Those instructions are available here. Component 1 data must be submitted by June 4, 2024. More information can be found here.
Key Takeaways:
Employers should determine if they qualify for the filing requirements by the EEOC. If your organization does qualify, you should make arrangements to file prior to the June 4, 2024 deadline to make sure you remain legally compliant and avoid all penalties associated with the rule.
