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Get Ready for the EEO-1, Component 2 Report

September 10, 2019
September is here and many employers subject to the EEO-1 reporting law are beginning to focus on the nuts and bolts of how to file the new EEO-1, Component 2, report. 
The EEO-1 form must be submitted by: 
  • employers of 100 or more employees, or
  • employers having 50 or more employees, and have a contract, subcontract, or purchase order amounting to $50,000 or more.
There are two additional minor categories of covered employers: 
  • Companies that serve as a depository of government funds in any amount, or
  • Any company that is a financial institution and an issuing and paying agent for U.S. Savings Bonds and Savings Notes.
While employers subject to the EEO-1 are familiar with the process, the component 2 aspect is new. Component 2 requires reporting of hours worked sorted by job category, pay band, race, ethnicity, and gender.  While it is not known what the final uses of all the data will be, the collection of pay data by the EEOC may be used to quantify gender or racial pay disaparities.
Component 2 data must be submitted for calendar year 2017 and calendar year 2018.
Data is submitted for a “snapshot period.”  Employers may select any pay period between October 1 and December 31 of the reporting year. The law does not require an employer to use the same snapshot period as was used for component one.
Data must be provided for all full- and part-time employees. The bulleted list below highlights the actual information employer will need to complete Component 2: 
  • Name 
  • Job Title
  • EEO-1 Category
  • Race
  • Sex
  • Location
  • W-2 Box 1 Wages 
  • FLSA status
  • FT/PT Status
  • # of hours worked
  • # of weeks “employed” for exempt workers
  • Date of hire if employees were hired in the reporting year
  • Date of termination (if employees termed during the reporting year) 
Prior to submission of the document a company official will need to assure that the information is accurate and prepared in accordance with the instructions. 
The information contained in the links below should help companies comply with the new EEO-1, Component 2 process.
Sample form (the proposed EEO-1 Form to collect pay data in the Component 2 EEO-1 Online Filing System).
Instruction booklet for filers (instructions for submitting the Component 2 EEO-1 Report).
Users' guide (instructions for using the Component 2 EEO-1 Online Filing System).
Frequently Asked Questions   
Reference documents (supporting reference materials including the job classification guide, 2017 NAICS codes, a Postal Code Lookup file).
AIM members with questions about this or any other HR-related issue may call the AIM employer Hotline at 1-800-470-6277.
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