What is the EEO-1 Component 2 data and how do I know if I have to report?
The EEO-1 annual compliance survey requires certain employers to report company employment data categorized by race/ethnicity and gender in each of 10 job categories.
Employers who file EEO-1 reports have already submitted what is now referred to as “Component 1” demographic data (race/ethnicity, gender) for calendar year 2018—but EEO-1 “Component 2” compensation data, covering pay and hours worked for calendar years 2017 and 2018, must be reported by September 30, 2019. This is the first year Component 2 data must be filed.
Both the Equal Employment Opportunity Commission (EEOC) and the Office of Federal Contract Compliance Programs (OFCCP) have used EEO-1 data since 1966 to assess private employers’ and government contractors’ women and minority workforce.
The EEOC has announced that it will not renew its request for authorization to collect Component 2 data in the future, but will continue to collect Component 1 data.
Here’s what you need to know for reporting EEO-1 Component 2 data this year.
Who Must Report?
All employers with 100 or more employees during what’s referred to as the “workforce snapshot period” in 2017—including federal contractors—are required to submit Component 2 data for 2017.
Similarly, employers and federal contractors with 100 or more employees during the workforce snapshot period for 2018 are required to submit Component 2 data for 2018.
An employer’s “workforce snapshot period” is an employer-selected pay period between October 1 and December 31 of the reporting year. For instance:
• A 2017 workforce snapshot period is an employer-selected pay period between October 1, 2017 and December 31, 2017.
• A 2018 workforce snapshot period is an employer-selected pay period between October 1, 2018 and December 31, 2018.
Employers must report the compensation and hours-worked data for full- and part-time employees on the employer’s payroll during the workforce snapshot period. Employers may choose a different workforce snapshot period for reporting Component 2 data for each of these years.
Also, employers may choose a different workforce snapshot period for reporting Component 2 data than what was used for EEO-1 Component 1 reporting for 2017 and 2018.
Unlike with Component 1 data, federal contractors with 50–99 employees are not required to report Component 2 data. Private employers with fewer than 100 employees and federal contractors with fewer than 50 employees aren’t required to file either EEO-1 Component 1 data or Component 2 data.
Reporting Component 2 Data
Employers must electronically report their Component 2 data through the EEOC’s Component 2 EEO-1 Online Filing System, or by creating and electronically submitting a data file containing their data in the appropriate fields in accordance with the data file specifications. The Component 2 data is reported under “Section D – Employment Data.”
Employers are encouraged to access the EEOC’s online portal at eeoccomp2.norc.org/Index and frequently asked questions, eeoccomp2.norc.org/Faq, for additional information on how to accurately report Component 2 data by the September 30, 2019, deadline, and consult legal counsel with any questions about how to comply.
More details also appear in the HRCalifornia Extra article.
Column based on questions asked by callers on the Labor Law Helpline, a service to California Chamber of Commerce preferred and executive members. For expert explanations of labor laws and Cal/OSHA regulations, not legal counsel for specific situations, call (800) 348-2262 or submit your question at www.hrcalifornia.com.
