Court Adopts September 30, 2019 as the Deadline for Covered Employers to Report EEO 1 Pay and Hours Worked Data to the EEOC

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On April 25, 2019, the U.S. District Court for the District of Columbia adopted September 30, 2019 as the deadline for covered employers to report data on employee W‑2 earnings and hours worked to the Equal Employment Opportunity Commission ("EEOC").

As previously reported in "New EEO‑1 Reporting Requirements Reinstated," the Court recently reinstated the EEO‑1 pay and hours worked data reporting requirements which were suspended by the federal Office of Management and Budget on August 29, 2017.  On April 16, 2019, the National Women's Law Center and the Labor Council for Latin American Advancement asked the Court to issue an order requiring the EEOC to collect employee pay data by the EEO‑1 filing deadline of May 31, 2019.  In response, the EEOC informed the Court it would be unable to collect the data by May 31, 2019, and proposed a September 30, 2019 deadline.  The Court accepted the EEOC's proposed deadline on April 25, 2019.

Although the EEOC may appeal the Court's original ruling reinstating the pay and hour data requirements, covered employers should not delay collecting pay and hours worked data.

We are monitoring this matter closely and will provide updates as new information becomes available.  If you have any questions regarding the new EEO‑1 reporting requirements, please contact Christopher K. Schuele or your Reinhart attorney.