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Employers Learn of September 30 Deadline to Submit Full Pay Data

Larger employers concerned about the deadline for submitting pay data to the Equal Employment Opportunity Commission (EEOC) recently learned that they must submit pay data by September 30, 2019. The U.S. District Court for the District of Columbia held on April 25, 2019, that employers with at least 100 employees must provide data to the EEOC by September 30, 2019. The opinion overturned the U.S. Office of Management and Budget’s previous attempt to stay Obama era EEO-1 reports, which require that companies share W-2 wage information and total hours worked. Nilan Johnson Lewis attorney Joe Schmitt says, “though this matter could be appealed, the regulation now states that employers must file EEO-1 Component 1 demographic data by May 31, with Component 2 data due September 30.” He says the above U.S. District Court opinion adds to six states that have adopted more robust pay equity and analysis laws and believes there’s a strong possibility more pay transparency rules and pressures could emerge from other state legislatures, state attorney general offices and activist shareholder groups amidst the #MeToo movement. “The latest report is vastly more complicated, so while most management teams are fine with releasing such information, they are not accustomed to it and want time to analyze and investigate the data,” says Schmitt. “They should start conducting internal pay audits soon, giving time to review the findings and address red flags if necessary.” Contact Joe Schmitt at 612.305.7577 or

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