EEO-1 Compliance Deadline, Component 2: September 30, 2019

EEO-1 Compliance Deadline, Component 2: September 30, 2019

The compliance deadline for Component 2 of the mandatory EEO-1 requirements for pay data is fast approaching on September 30, 2019.

In April 2019, a federal judge announced a ruling that requires employers to collect employee pay data and hours worked by race, ethnicity and gender and submit it to the U.S. Equal Employment Opportunity Commission (EE0C) by this date.

The EEO-1 requirements consist of two components:

  • Component 1 data is the racial/ethnic and gender composition of an employer’s workforce by specific job categories.
  • Component 2 data is hours worked and pay data for 2017 & 2018. 

Employers can submit the Component 2 information at the EEOCComp2-website by data file upload, or by completing the online form, which opened in July 2019.

Likewise, employers file the Component 1 information through the website, via their Online Filing System, which opened in March 2019.

Who Needs to Submit EEO-1 Data?

 All employers that have at least 100 employees are required to file Component 1 data reports annually with the EEOC and file Component 2 data in 2019 (for 2017 and 2018).

Federal government contractors and first-tier subcontractors with 50 or more employees and at least $50,000 in contracts must file only Component 1 data reports.

Federal contractors with 1-49 employees, and other private employers with 1-99 employees, are not required to file either EEO-1 Component 1 data or component 2 data.

If EEO-1 reporting would cause undue hardship, employers may request an exemption or a one-time 30-day extension of the EEO-1 filing deadlines by emailing a request to the EEOC at

Help and More Information About EEOC compliance:

The EEOC has contracted with NORC at the University of Chicago to conduct the Component 2 EEO-1 Compensation Data Collection for 2017 and 2018.

Additional resources for filers, including Frequently Asked Questions (FAQs), Sample Data Collection Form, Instruction Booklet for Filers, User’s Guide, Fact Sheet, and more, is available at

As HR consultants for 40+ years, The Kirwan Companies is expert at answering questions about compliance and guiding our clients through new processes, forms and guidelines. Please let us know how we can help you.

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