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EEO-1 Component 2/Pay Data Reporting

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The Equal Employment Opportunity Commission (EEOC) and its contractor (NORC at the University of Chicago) issued the long-awaited resource documents in early July on how to submit EEO-1 Component 2 compensation data for fiscal years 2017 and 2018. The web-based portal for upload submission of the Component 2 data became active on August 15, 2019. Since the release of the resource documents, Avionté has been working diligently to construct a Federal EEO Component 2 Reporting AQ and we are happy to provide this to our clients for federal reporting. Made available in the August release for hosted clients, self-hosted clients will need to upgrade or create a ticket request to have the AQ deployed.



For over 50 years, the EEOC has required employers with more than 100 employees to report the number of their employees by sex, race/ethnicity, and job category through its Employer Information Report, more commonly known as the EEO-1. In February 2016, the EEOC published a notice in the Federal Register announcing its intention to revise the EEO-1 data collection and begin collecting pay data as well. The revised EEO-1 form (component 2) requires employers to report W-2 wage information within 12 pay bands and total hours worked for all employees by sex, race/ethnicity, and job category.

The collection of pay data was to begin in 2017 with the first pay data reports (for 2017) due in March 2018. In August 2017, however, The Office Of Management and Budget (OMB) reversed course and told EEOC it had decided to initiate a review and stay of the pay data collection due to concerns that “some aspects of the revised collection of information lack practical utility, are unnecessarily burdensome, and do not adequately address privacy and confidentiality issues.”

In November 2017, pay equity advocates initiated litigation seeking vacation of the stay and reinstatement of the pay data collection requirements. The US District Court for the District of Columbia granted this request, and Judge Tanya Chutkan ordered the EEOC to collect employer pay data by September 30, 2019.




Employers with 100 or more employees must report employee compensation data for fiscal years 2017 and 2018. Compensation data includes W-2 wage information and hours worked, broken out by gender, race/ethnicity, and job category. Employers must report this data for ALL full-time and part-time employees who were employed during the “workforce snapshot period,” an employer-selected pay period between October 1 and December 31 of the reporting year. The Component 2 EEO-1 Online Filing System Sample Form illustrates how the data will be collected.

Employers who have multiple establishments must file a report for the headquarters and each establishment with 50 or more employees, and an establishment report or establishment list for locations with less than 50 employees.

Additionally, the EEOC released FAQs regarding the EEO-1 Component 2 pay data, found here, as well as more resources related to the 2017 and 2018 Component 2 Pay Data filing, here.



Referencing our Industry Experts the American Staffing Association (ASA), the organization has suggested that temporary employees hired via staffing agencies are exempt from EEO reporting. ASA members can utilize the ASA resources for further in-depth information regarding this topic. ASA Members: There is a presentation linked here, as well as an ASA central discussion from this year where ASA counsel addresses EEO-1 reporting of temporary workers and staffing agencies. Please note, in sharing these resources Avionté makes no legal recommendations regarding EEO reporting, and this section is intended for client reference to review with appropriate legal counsel. Discuss with legal counsel prior to making any decisions around EEO reporting.




Avionté clients can prepare to file the EEO-1 Component 2 Pay Data Report by reviewing their current employees’ configurations and confirming that employees are assigned an EEO class, gender, and ethnicity. If an employee has not previously indicated their ethnicity or gender, an employer is permitted by the EEOC to perform a visual survey of the employee or to use prior employment records to assign an ethnicity or gender to the employee.

Clients can run the “Federal EEO Component 2 Reporting AQ” to assist in the preparation of employee filing data. EEO reports are part of the Standard Advanced Queries provided by Avionté. Below is a view of the report and its parameters:






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