The Equal Employment Opportunity Commission (EEOC) requires all employers with 100 or more employees, and federal contractors with 50 or more employees and contracts of $50,000 or more, to provide information about the makeup of their workforce. Form EEO-1 must be filed annually to identify employees by race, ethnicity and sex, in each employer location and job category (Component 1 data). Employers with 100 or more employees have an additional obligation to report pay data for their workforce (Component 2 data).
The Equal Pay Act of 1963 requires that employers pay men and women in the same workplace equal pay for equal work. Even if the jobs for men and women are not identical, if they are substantially similar, they require equal pay. Job content, not job title, determines whether a position is substantially similar to another position. The EEOC is now requesting pay data as a tool for it to use to identify possible pay discrimination and to help employers maintain equal pay throughout their workforce.
After many extensions, the EEOC initially set a deadline of September 30, 2019 for employers with 100 or more employees to report Component 2 pay data for the 2017 and 2018 calendar years. That deadline has been extended, and most recently the EEOC announced that employers must submit their Component 2 data by November 11, 2019.
Employers that are subject to Component 2 reporting should make sure to file their information before the November 11, 2019 compliance date. Information to help with reporting may be found by clicking here.