The U.S. Equal Employment Opportunity Commission (EEOC) has issued revisions requiring employers with at least 100 employees to submit annual EEO-1 reports that include W-2 pay and hours worked data for their entire workforces, nationwide.
Armed with the data, and intent upon identifying pay disparities causing the “wage gap” for women and minorities, the EEOC and the Office of Federal Contract Compliance Programs (OFCCP) will monitor and test employer data and investigate in detail the pay practices of those employers whose data suggests indefensible pay disparities.
The first modified reports will not be filed until the first quarter of 2018. Rather than file EEO-1 reports as usual in the fall of 2017, the revised EEO-1 pay data report will be filed by March 31, 2018 (EEO-1 reports for 2016 will be filed as usual without pay data).
Employers are advised to begin preparations now, starting with pay analyses to identify and address pay issues that could emerge from the EEO-1 pay data and arise in systemic investigations by EEOC or OFCCP.