4/14/22: Covered Employers May Now Report 2021 EEO-1 Component 1 Data (Are You Covered? And What Will You be Reporting?)
April 14, 2022
By Paula Barran
This week, the U.S. Equal Employment Opportunity Commission (“EEOC”) announced that the 2021 EEO-1 Component 1 data collection process is now open, and this year’s deadline is May 17.
The EEO-1 Component 1 Report reflects an annual data collection requirement imposed on certain private and federal employers, and seeks demographic workforce data, including race/ethnicity, sex, and job categories. Following the May 17 deadline, the EEOC will enter the “failure to file” phase until June 21, 2022.
There is also a new filer support system to streamline the process. The Filer Support Team Message Center allows filers to submit, update, track, and terminate requests for assistance; and provides a number of self-service capabilities.
Let’s unpack this message:
Who Must File a Report?
Subject to certain exemptions, these requirements apply to the following:
Private employers with 100 or more employees;
Private employers with fewer than 100 employees, if the company is owned or affiliated with another company, or there is centralized ownership, control or management, such that they legally constitute a single enterprise and the entire enterprise employs 100 or more employees; and
Federal contractors with 50 or more employees.
If you received an EEO-1 Component 1 notification letter, but you do not believe you are required to report, you must access the EEO-1 Component 1 Online Filing System to complete the eligibility screener and confirm your status.
What Information Do You Need to Collect?
If you are required to participate, you need to collect and submit a “workforce snapshot” for all full-time and part-time employees (including those who worked remotely), during the timeframe specified by the EEOC. The workforce snapshot includes information such as employee demographics and job categories.
How Will You Collect the Required Data?
You are required to offer employees the opportunity to use self-identification to complete the Report. If an employee declines to self-identify race and/or ethnicity, employment records or observer (visual) identification may be used to complete the Report.
A Note for Third-Party Human Resource Organizations:
In February, the EEOC announced updated procedures for third-party human resource organizations. Among other things, third-party human resource organizations may not submit a Report that includes itself and a client employer, or a Report that includes multiple client employers. For more information as to the updated procedures, see the EEOC’s Fact Sheet for Third-Party Human Resource Organization Reporting Procedures (including PEOs).
For questions about EEO-1 Component 1 Data Collection or for any other employment-related questions, contact Paula Barran at 503-228-0500, or at pbarran@barran.com.
