The Equal Employment Opportunity Commission (EEOC) told a federal judge on April 3, 2019 that it was unable to collect pay data (also known as Component – 2 data) from employers by the EEO-1 filing deadline of May 31, 2019. The EEOC proposed that the agency could collect the pay data by September 30, 2019 for the 2018 period, if the agency can use private third party contractors to collect the data.


The cost of carrying out the EEOC proposal is expected to cost over $3 million. The EEOC also gave a warning of the risks of collecting both 2017 and 2018 pay data stating, “There is a serious risk the expedited data collection may yield poor quality data because of the limited quality control and quality assurance measures that would be implemented due to the expedited timeline. A response to the EEOC proposal is expected on Monday, April 8 and soon after the court is expected to make a decision on the pay data collection.



In February 2016, The EEOC announced a proposal to revise the EEO-1 reporting to include pay data in addition to the data already collected (Component-1 data). The collection was to provide pay data reports for 2017 which were to be included on the EEO-1 report due in March of 2018.  However, in August 2017 the Office of management and Budget (OMB) issued a stay on the pay data collection due to a number of concerns with the collection of the pay data.


In November 2017 supporters of the pay data collection filed a suit requesting that the stay be vacated and on March 4, 2018 the U.S. District Court for the District of Columbia vacated the White House Office of Management and Budget’s (OMB) stay of the revised EEO-1 form’s pay data reporting requirements.  


Next Steps

Employers with 100 or more employees and federal contractors with 50 or more employees and contract over $50,000 are still required to collect and report Component-1 data (race, gender, ethnicity and job category) on the Employer Information Report, EEO-1 by the May 31, 2019 deadline.

Paylocity will continue to monitor the court actions regarding the Component-2 Pay data collection and reporting requirements and will provide updates when available.


Once it is clear if the pay data will be required and when employers must collect and report the pay data, Paylocity will update our EEO-1 report to include the required pay data information. The current report does not include Pay Data information. The EEO-1 report is included in the Reports Library.


Thank you for choosing Paylocity as your Payroll Tax and Human Capital management partner.


This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a Payroll Service Provider are encouraged to seek the advice of a qualified CPA, Tax Attorney or Advisor.