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Take this off your fall ‘to do’ list: EEO-1 delayed in part and suspended in part

by Brian Bouchard

As you may have heard, we recently received some good news regarding the EEO-1 pay data collection that would have gone into effect in March 2018. 

On August 29, acting chair of the Equal Employment Opportunity Commission (EEOC) Victoria Lipnic issued a statement indicating that the Office of Information and Regulatory Affairs (OIRA) plans to delay the effective date of the pay data collection provisions of the revised EEO-1 form in order to review the appropriateness of the revisions under the Paperwork Reduction Act (PRA).

The original EEO-1 obligations haven’t changed, but employers won’t need to report on wages or hours worked. In other words, the EEOC postponed the rollout of its new reporting form “Component 2,” which would have required the reporting of wages and hours worked. Both Component 1 (the original EEO-1 reporting form, which requires the disclosure of race, ethnicity, and gender) and Component 2 were originally scheduled for a filing date of March 2018. (EEO-1 used to be due in October each year for the period ending September 30).

That March 2018 deadline hasn’t changed for Component 1. Component 2 however has been postponed, maybe indefinitely. So to be clear, for employers with 100 or more employees, the EEO-1 reporting deadline is still March 2018, but you only need to submit Component 1 (the original EEO-1 reporting attorney photo for printform).

Brian Bouchard is an attorney with Sheehan Phinney Bass & Green PA, practicing in the firm’s Manchester, New Hampshire, office. He is also a frequent contributor to New Hampshire Employment Law Letter. He may be contacted at

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