UPDATED: Federal District Court Reinstates EEO-1 Pay Data Reporting Requirements (For Now)
By: Amanda Thibodeau
As we previously reported, in March 2019 the U.S. District Court for the District of Columbia issued a ruling concluding that the White House Office of Management and Budget (“OMB”) did not have a sufficient basis to stay pay reporting data requirements (known as “Component 2”) previously announced by the U.S. Equal Employment Opportunity Commission (“EEOC”).
On April 3, 2019 the OMB filed a brief with the U.S. District Court for the District of Columbia proposing a September 30, 2019 deadline for the EEOC to complete the Component 2 pay data collection, which was approved by the Court later that month.
On May 1, 2019, the EEOC announced it expects to begin collecting the Component 2 pay data for both 2017 and 2018 calendar years in mid-July 2019 in anticipation of the September 30, 2019 deadline. The EEOC expects to open a submission portal for employers to submit that data this summer. A copy of the published announcement can be found here.
Employers are still expected to submit their 2018 Component 1 data by the May 31, 2019 deadline.
The Morse Employment Law Group will continue to monitor this issue and provide updates as they become available.
For more information, please contact Matthew Mitchell or Amanda Thibodeau.
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