The Final Countdown: Ten Days Until the EEO-1 Component 2 Pay Data Deadline

This is a reminder to covered employers that the September 30, 2019, deadline for filing the EEO-1 Component 2 Data is just 10 days away. At this point, it’s not clear what the consequences of failing to submit the pay data will be, and to the extent there are any, if the consequences will have teeth.

The Equal Employment Opportunity Commission (EEOC) outsourced the collection of the Component 2 Data for 2017 and 2018 to NORC, at the University of Chicago, an independent research institution. Employers with questions or issues can contact NORC at (877) 324-6214, or send an email to [email protected]. The EEOC NORC page, updated on September 17, 2019, indicates that the EEOC Help Desk hours has been extended, due to the high volume of daily calls and emails. Updated hours are Central Time, Monday through Friday, 8:00 a.m. to 8:00 p.m., Saturdays 10:00 a.m. to 4:00 p.m., and Sunday 12:00 p.m. to 5:00 p.m.

NORC and the EEOC have very specific, detailed specifications on how the data is to be downloaded, and how to verify the filings. Employers can visit the EEOC website for a sample form, instruction booklet, and frequently asked questions for covered employers.

Ironically, although Component 2 Data must still be submitted by September 30th for 2017 and 2018, the EEOC recently announced that it will not collect the pay data in the future, after concluding that the burden imposed on employers to gather the information “outweighs the usefulness of the data for the agency.” However, that decision may well be challenged, as in 2017 when the Federal government announced its intention not to gather Component 2 Data.

If you have any questions about the EEO-2 reporting requirements, please contact us.