Soon remembering what a “normal” EEO-1 filing season is like will become the mark of a seasoned veteran in the EEO/AA industry. From the rise and fall of “Component 2” compensation data reporting to delays due to the coronavirus pandemic, EEO-1 reporting has been modified, filing dates changed, modified again, and delayed several times. But it looks like the EEOC is gearing up for the 2019/2020 filing season, which is slated to begin next week on Monday, April 26, 2020, by launching a revamped EEO-1 landing page.
When the EEOC implemented the “Component 2” compensation data collection the filing deadline was necessarily moved from September 30 to March 31. When the pay data collection was suspended after collecting data for calendar years 2017 and 2018, the new filing deadline remained in place even though it was only necessary because of the pay data reporting requirement. So 2019 data should have been reported by March 31, 2020, but in the meantime a worldwide pandemic hit, and the 2019 filing was suspended.
Here we are now in 2021 and the EEOC is trying to gather 2019 and 2020 data. The pandemic is not anywhere near being “over,” but the majority of employers have figured out how to work within ever-changing health and safety guidelines. So the EEOC is moving ahead, though the filing deadline this year has already been extended three and a half months out to Monday, July 19, 2021.
Get Ready?
The new EEO-1 landing page looks nice, but is missing some key guidance documents filers tend to rely upon. For instance, the EEO-1 Instruction Booklet has been the bedrock for EEO-1 filers for years. The Instruction Booklet was taken down several months ago, presumably for revision, but as of this writing still has yet to be re-posted.
In addition, the EEOC has very quietly phased out reporting by paper form over the last several years. Filers are now given only two options for filing: either fill-out an online form for each EEO-1 report; or upload specially formatted data files. Trouble is, the EEOC has not provided final formatting requirements for these data upload files. According to the new website, the upload instructions will be provided “in April 2021.” With the filing season opening in just a few days, the EEOC needs to get a wiggle on.
If you use a vendor to file your EEO-1 reports, be sure to forward them the notification letter when you receive it. This letter will contain the company ID and passcode for accessing the online filing system. If your organization has not received the notification letter by the time the filing season opens, contact the EEOC.
And as always, if you have questions about your EEO-1 filing obligations, feel free to contact us at bcgi@biddle.com.
