EEO-1 Component 2 Pay Data Report Due Sept. 30, 2019

October 02, 2019

The EEOC has announced that it will continue to accept EEO-1 Component 2 data for 2017 and 2018 until it has met the target response rate.

• The EEOC has announced that it will continue to accept EEO-1 Component 2 data for 2017 and 2018 until it has met the target response rate.

• The official filing deadline is still September 30, 2019 when employers must file online.

• The EEO-1 Component 2 Pay Data Report is available in the Reports Library.

• The report must be filed for both 2017 and 2018 pay data.

• The EEOC will not seek to renew the collection of Pay Data for future years.

Updated EEOC Guidance

On September 27, 2019 the EEOC stated in Status Report that as long as the court order from the recent National Women’s Law Center, et a., v. Office of Management and Budget, et al. is in effect, the EEO-1 component 2 data collection is not complete until it reaches what the Court has determined to be the target response rate. The EEOC will continue to accept Component 2 data for 2017 and 2018 and encourages all employers to submit their data as soon as possible.

The data collection will not be completed until the percentage of EEO-1 Component 2 Pay Data reports filed equals or exceeds the EEO-1 reports filed in the past 4 years.

At this time the agency is also experiencing a high call volume and has extended the helpdesk hours to accommodate additional calls and emails.

Employer Requirements

Subject employers are required to file the 2017 and 2018 pay data through the online portal, The compensation data report must be filed either online on or before the September 30, 2019 deadline.

Employers are required to file for both 2017 and 2018, if they met the employee threshold or are subject to file under federal law. The measurement period is between October and December of each year. The agency will not provide pre-population of historical data on the report from the 2017 or 2018 EEO-1 Component 1 report that was filed earlier this year in May.

Employers are required to report aggregated data by pay band and job category for compensation as reported on the W-2, hours worked, gender, and ethnicity.

Employers who have multiple establishments must file a report for the headquarters and each establishment with 50 or more employees, and an establishment report or establishment list for locations with less than 50 employees.

Additional resources are available in PEAK under PCTY-77089 EEO-1 Component 2 Report Overview.

Future of EEO-1 Pay Data Reporting

On September 11, 2019, the EEOC announced that it will not seek to renew collection of EEO-1 Component 2 Data for future years. The EEOC stated that its 2016 methodology to calculate the burden to employers in completing EEO-1 reports, including component 2, was flawed.

 The EEOC stated, “It must balance the utility of the data to its enforcement programs against the burden the data collection as structured imposes on the employers who must submit it.” The EEOC summarized “it should consider the information from the ongoing Component 2 data collection before deciding whether to submit a pay data collection to OMB. At this point in time, the unproven utility to its enforcement program of the pay data as defined in the 2016 Component 2 is far outweighed by the burden imposed on employers that must comply with the reporting obligation. Therefore, the EEOC is not seeking to renew Component 2 of the EEO-1.”


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.