The collection period for the newly required EEO-1 pay data, also called Component 2, has been extended until January 31, 2020. If employers missed the original deadline of September 30, 2019, they should still work to submit company pay data.
The original April ruling on pay data collection stated the collection “will not be deemed complete … until the percentage of EEO-1 reporters that have submitted their required EEO-1 Component 2 reports equals or exceeds the mean percentage of EEO-1 reporters that actually submitted EEO-1 reports in each of the past four reporting years." This specification caused dispute over whether the “mean” was the average percentage of total pay data submitted or the average data submitted by the deadline.
Despite requests from the Equal Employment Opportunity Commission (EEOC) to consider pay data collection complete, a judge recently ruled the EEOC “must continue to take all steps necessary” to reach the collection goal by the new deadline.
The deadline extension and pressure on the EEOC makes Component 2 submission more important for employers to avoid potential warnings and sanctions. As stated in previous notices, this requirement includes companies with over 100 employees as well as federal contractors with 50 or more employees.