Comply with the EEO-1 Report Component 2 Reporting Checklist
Author: XpertHR Editorial Team
When to Use
The EEO-1 Report Component 2 reports on employee compensation and hours worked from covered employers with 100 or more employees sorted by job category, pay band, race, ethnicity and gender. It differs from the EEO-1 Report Component 1 reporting (which was due by May 31, 2019) on the gender, racial and ethnic makeup of an employer's workforce. In light of the recent court decision in National Women's Law Center, et al., v. Office of Management and Budget, et al., +358 F. Supp. 3d 66 (D.D.C.), the Equal Employment Opportunity Commission (EEOC) will collect Component 2 data for 2017 and 2018 by September 30, 2019. The EEOC will begin collecting this data in mid-July, 2019.
The following checklist may be used to help an employer comply with EEO-1 Component 2 reporting requirements. Employers should complete the following steps in sequential order.
Comply with EEO-1 Report Component 2 Reporting Checklist
1. Pick a Workforce Snapshot Period
- Choose one single payroll period between October and December 31 of each reporting year (e.g., 2017 and 2018) known as the workforce snapshot period.
- Recognize that the workforce snapshot period does not need to be the same for different years (e.g., 2017 and 2018), and it does not need to be the same pay period used for submitting Component 1 data.
2. Determine if an EEO-1 Report Component 2 Must Be Filed
- Determine if the employer, or federal contractor, has 100 or more employees during the chosen 2017 workforce snapshot period which would require filing EEO-1 Report Component 2 information for 2017.
- Determine if the employer, or federal contractor, has 100 or more employees during the chosen 2018 workforce snapshot period which would require filing EEO-1 Report Component 2 information for 2018.
- Understand that the following employers do not need to file EEO-1 Report Component 2 data:
- Federal contractors with 50-99 employees are not required to report Component 2 compensation data.
- Federal contractors with 1-49 employees, and other private employers with 1-99 employees, are not required to file either EEO-1 Component 1 data or Component 2 data.
3. Determine Which EEO-1 Report Component 2 Reports Must Be Filed
- Determine if the organization is a single-establishment employer or a multi-establishment employer.
- Understand that a single-establishment must complete a single Component 2 EEO-1 online data record.
- Recognize that multi-establishment employers must submit compensation data for all establishments and file the following:
- A Consolidated Report, which includes summary pay and hours worked data for employees in the organization's headquarters and at each establishment;
- An individual report for each establishment with 50 or more employees; and
- An establishment list or establishment report, similar to the list or report required for Component 1, for establishments with fewer than 50 employees.
4. Extract Data and Compile Information on Compensation and Hours Worked
- Understand that compensation and hours worked data only needs to be reported for those employees who are full-time and part-time employees who were on the employer's payroll during the workforce snapshot period.
- Report W-2 Box 1 earnings for the year for all employees identified in the workforce snapshot period, even if the employee is no longer employed at the end of the year.
- Tally the total number of employees who fall into each of the 12 specific compensation bands by EEO-1 job category, gender and race/ethnicity.
- Report hours worked, in the aggregate, for all employees in the snapshot period, by gender and race/ethnicity.
- For nonexempt employees within the meaning of the Fair Labor Standards Act (FLSA), report the annual sum of hours each nonexempt employee worked.
- For FLSA-exempt employees, an employer may either: (1) report actual hours worked by the exempt employees if the employer already maintains accurate records of this information; or (2) report a proxy of 40 hours per week for full-time exempt employees and 20 hours per week for part-time exempt employees, multiplied by the number of weeks the employees were employed during the EEO-1 reporting year.
5. File EEO-1 Component 2 Information Online
- Submit the EEO-Component 2 Report via the Component 2 EEO-1 Online Filing System, or by creating a CSV data file and inputting data in the appropriate fields in accordance with the data file specifications.
- Take proper precautions to protect such information as all internet-based communications may be subject to tampering from an outside source.
An employer does not need to choose a pay period in which it has 100 or more employees. Component 2 data will only be submitted for employees employed during the workforce snapshot period for each of the relevant reporting years.
An employer will receive its User ID via a notification letter mailed through the US Postal Service and an email sent to the registered EEO-1 email address on record. A password will be set up during initial entry into the system, after the employer's User ID, Federal Employer Identification Number (FEIN), and email address have been verified.
Employers will be unable to access their 2017 and 2018 Component 1 reports in the Component 2 EEO-1 online filing system
Employers should understand that although all data is encrypted, employers must protect the privacy of the information they are filing.
Once all reports have been completed for the organization, the authorized official for the employer must certify that the information reported is accurate and prepared in accordance with the instructions.