HR and Payroll Guidance for Leadership Teams

Proposed EEO-1 Reporting: What You Need to Know

Tax return papers

Earlier this year, the Equal Employment Opportunity Commission (EEOC) proposed that some employers be required to submit employee pay data in a new EEO-1 report.

This data would help the EEOC enforce federal pay discrimination laws and cut down on discriminatory pay practices within the workplace.

If approved, the new EEO-1 report would go into effect for the September 30, 2017 filing deadline.


The new EEO-1 report would require private employers and federal contractors with  100 or more employees to submit employee pay data along with current EEO-1 requirements, which include number of employees by job category and by race, ethnicity and sex.

To collect pay data, employers would need to identify employees’ total W-2 earnings for a 12-month period looking back from a pay period between July 1 and September 30.

This data would then be used to group employees into one of twelve designated pay bands.

In addition to W-2 earnings, employers would also need to report the number of hours worked by employees in each pay band.

View an example of the proposed report.

Federal contractors with 50 to 99 employees and private employers with less than 99 employees would not be required to submit pay data but would still need to submit current data requirements.

Next Steps

Following a 60-day comment period that ends April 1, the EEOC will hold a public hearing on the proposal and then submit a finalized version to the Office of Budget and Management (OMB) for review.

If approved, the EEOC will post a notice on its website and notify current EEO-1 respondents of the revised report.

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