By William Collins and Robert G. Brody
The Equal Employment Opportunity Commission (EEOC) collects workforce data on sex and race /ethnicity by type of job grouping. The 2024 EEO-1 Component 1 data (employer information report) is due on Tuesday, June 24, 2025. Employers who meet the reporting thresholds have a legal obligation to provide the EEOC with this data.
Who must file a report?
- Private employers with 100 or more employees and
- Federal Contractors with 50 or more employees and at least $50,000 in government contracts.
What information should be included?
Employers who meet the threshold must collect employee demographic information. This includes all employee’s sex, race, and ethnicity. The employees should also be categorized by job type (e.g., management). However, based on President Trump’s recent Executive Order 14168, titled “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government,” there is no longer the option to report employees as non-binary. A few other limited changes were made.
How to file?
Employers should visit the EEO-1 Component 1 website, www.eeocdata.org/eeo1, to access the new Online Filing System (OFS). The website provides additional instructions and upload specifications. A filer requiring additional assistance can access the Filer Support Team Message Center by logging into the OFS.
Impact of Executive Orders?
EEO-1 reports have previously been used to identify the disparate impact of neutral practices on employees based on race, sex and other protected characteristics. However, in line with Executive Order titled “Restoring Quality of Opportunity and Meritocracy” Andrea Luca, Acting Chair of the EEOC, plans to deprioritize disparate impact claims instead focusing on intentional discrimination claims. There is a lack of information on how this will be done, but EEO-1 reports may also assist the EEOC in identifying claims of intentional discrimination. As such Employers must still actively address issues and submit their EEO-1 reports before the deadline of June 24th.
Brody and Associates regularly advises management on complying with the latest local, state, and federal employment laws. If we can be of assistance in this area, please contact us at info@brodyandassociates.com or 203.454.0560.
