By A. Edward Hardin, Jr.

As was previously reported, in March, a Federal District Judge in Washington D.C. lifted a stay on the EEOC’s collection of pay data (known as “Component 2” data) from employers with EEO-1 reporting obligations.  The EEOC has now spoken regarding its collection of Component 2 data and stated that covered employers will be required to submit Component 2 data for both calendar years 2017 and 2018 by September 30, 2019.  Component 2 data includes information concerning hours worked and employee pay.  On its website, the EEOC specifically noted that covered employers must submit 2018 Component 1 data (i.e, numbers of employees by job category, race, ethnicity, and sex) by May 31, 2019.  The September 30, 2019 deadline does not upset the May 31 reporting deadline for Component 1 data.  Most private employers with 100 or more employees must comply with the EEO-1 reporting obligations.