Legal Blog

HR Tips: Breaking Down the EEOC’s New Requirements and Online Reporting

Compliance. Reporting. Fines. For most employers, records are a part of life. For organizations with more than 100 employees, new requirements were recently announced by the Equal Opportunity Employment Commission (EEOC). Luckily, as of July 15, employers can create accounts and report online. Below are Human Resources (HR) tips on the online portal and EEO-1 and the new EEO-2 pay data requirements:

  1. Check out the new online portal for familiarity. The new portal became available on July 15, 2019, and is accessible here. Pay data must be reported no later than September 30, 2019.
  2. Begin to gather pay data now. The new EEO-2 requirements significantly expand the EEO-1 pay data by requesting information on employees’ gender, race, and ethnicity as it specifically relates to salary bands. Further, the EEOC mandates that both 2017 and 2018 data is reported. If you do not have this information readily available, now is the time to gather, organize, and proof before September’s deadline.
  3. The new requirement is not impacted by the DOJ’s pending appeal. As you may have heard, the Department of Justice has filed an appeal in the case of Nat’l Women’s Law Ctr. v. OMB,358 F. Supp. 3d 66 (D.D.C. 2019), which originally gave rise to the EEOC’s imposition of the EEO-2 requirement in March 2019. The Nat’l Women’s case was filed by plaintiffs challenging the government’s decision to stay or “pause” the collection of pay data. The government’s appeal, however, does not impact the required reporting. In fact, employers that refuse to report will be subject to fines and other penalties by the EEOC.


Given the additional requirements imposed with EEO-2, I recommend that you ensure that your organization’s pay data has been gathered and is ready for submission sooner than later. Feel free to reach out to me to discuss pay data compliance and other governmental requirements at or 703-745-1849.




Theodora Stringham assists individuals, businesses, and organizations with growing successfully while minimizing liability. Focusing on real estate and personnel needs, Ms. Stringham executes sustainable plans for real estate development and employee matters. She provides comprehensive representation for everyday growth issues, including, but not limited to, re-zonings, site plan approvals, eminent domain/valuation concerns, employment discrimination, and disciplinary issues. Ms. Stringham’s scope of representation ranges from identifying potential liability and providing counseling/trainings, all the way through representation at trial.






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