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On July 13, 2016, the Equal Employment Opportunity Commission (“EEOC”) proposed additional changes to EEO-1 data reporting requirements, modifying its original proposal from January 2016. The original proposal, intended to enforce the prohibitions on pay discrimination in Title VII, the EPA and Executive Order 11246 regarding Equal Employment Opportunity, required employers to begin reporting pay data. The proposed new EEO-1 would require large employers with 100 or more employees, including federal contractors, to report pay data for employees by race, gender and ethnicity. The most recent proposal builds on and slightly modifies the requirements proposed in January.
The EEOC’s new proposal requires large employers to report the number of employees by race, gender and ethnicity that are paid within each of 12 designated pay ranges set by the EEOC. Additionally, it requires reporting regarding hours worked by employees. The EEOC also proposes moving the implementation date for the new EEO-1 form from September 30, 2017 to March 31, 2018. This extension will permit employers to use existing W-2 pay information to complete the new EEO-1 forms.
If the proposed changes to the EEO-1 form go into effect, large employers may expect the EEOC to consider the reported pay data when investigating complaints of discrimination. The EEOC’s newest revision was spurred by a public comment period, during which the EEOC received hundreds of responses to its proposed changes earlier in the year. As a result of the EEOC’s further changes to its proposal, the EEOC is providing an additional 30-day comment period for the public to respond to the additional changes.