Regulatory Compliance

EEO-1 Compliance Requires
Pay Data Reporting

Contact TRUSAIC to Get It Done For You
By The EEOC Deadline of January 31, 2020

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The Equal Employment Opportunity Commission (EEOC) requires submission of the EEO-1 Report as part of its efforts to enforce equal opportunity laws. For 2019, the EEOC added a pay data reporting obligation is known as “Component 2,” which was designed to facilitate enforcement specifically in the area of pay discrimination. The 2019 reporting deadline was for the 2017 and 2018 years.

A recent court ruling has extended the Component 2 deadline to January 31, 2020.


Let TRUSAIC Do It For You

Trusaic supports employers in completing and filing Component 2 with the following:

  • Identify the company-level and employee-level data required for EEO-1 reporting, e.g., selection of Workforce Snapshot Period(s) and collection of establishment, job category, gender, race/ethnicity, wage, and hours-worked data;


  • Reconcile missing and/or inconsistent data;


  • Coordinate the EEO-1 Component 2 data file upload for submission to the EEOC via the NORC Online Portal; and


  • Provide a Pay Gap Risk Assessment to determine the magnitude and significance of any pay gaps that the EEOC may infer from the EEO-1 Component 2 data.


To use Trusaic’s EEO-1 Report Component 2 Reporting Service, employers must meet the following conditions:

  • Sign up before December 13, 2019.


  • Provide required pay data in a format acceptable to Trusaic by January 6, 2020, for reporting years 2017 and 2018.


  • Obtain a User ID needed to access the NORC portal (if not already received).


  • Certify data to the EEOC during upload to NORC portal.

Know Before You Show

Experts from various HR, payroll, human capital, and legal organizations strongly recommend that employers subject to the expanded EEO-1 requirements undertake a pay equity audit as soon as possible. The addition of new pay data requirements will give the EEOC an unprecedented view into your organization’s pay practices and may expose it to EEOC investigations and/or charges of unequal pay. Another reason to consider a pay equity audit is that your organization’s pay data is vulnerable to disclosure to third parties under several federal statutes. In either scenario, it’s better that you understand the risks posed by pay inequity in your data—and begin taking actions to mitigate them.

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Beware of Third-Party Access to
Your EEO-1 Pay Data

Employees, former employees and other third parties may gain access to your organization’s EEO-1 report(s), including pay data, if they have initiated a “proceeding” under Title VII of the Civil Rights Act of 1964 or the Americans with Disabilities Act.

For federal contractors, EEO-1 reports may also be obtained by the general public under Freedom of Information Act (FOIA) requests to the Office of Federal Contract Compliance Programs (OFCCP). According to the OFCCP, “the EEO‐1 data received by OFCCP are subject to the provisions of FOIA, meaning that members of the public may file a FOIA request asking OFCCP to disclose information in its possession.”

Now is the time to consider being proactive in identifying any pay disparities within your organization's pay structure and to develop a plan to address them.

TRUSAIC Recommended Best Practices:

  • Protect the pay equity audit with attorney-client privilege by working under the direction of inside or outside counsel.
  • Perform the pay equity audit pro-actively, to be able to respond to any apparent pay gaps that might catch the attention of the EEOC or other regulators.
  • Pro-actively formulate a response addressing any identified pay disparities.
  • For more information on EEO-1 reporting, subscribe to our blog, the PayParitySM Post, by clicking here.


The EEO-1 Report applies to two categories of employers:

  • Private employers with 100 or more employees.
  • Federal government contractors and subcontractors with 50 or more employees and with $50,000 or more in government contracts.

Why It Matters

  • Failure to file may result in EEOC enforcement, and filings with false statements may result in fines or imprisonment.
  • Inaccurate reporting may increase the appearance of pay discrimination, attracting agency scrutiny.
  • Inaccurate reporting may result in EEOC investigation, and/or employee lawsuits for pay discrimination.
  • Inaccurate reporting may negatively impact employee morale as well as company brand and reputation.

Accurate and complete EEO-1 reporting is designed to:

  • Avoid needless EEOC investigations and/or enforcement actions.
  • Avoid OFCCP audits for federal contractors.
  • Provide an opportunity to employers to conduct a self-assessment and proactive remediation.


Click below to download and view the current EEO-1 form for Component 1 data and the new form for Component 2 data.

Current EEO-1 Report

Proposed EEO-1 Report

For more information on EEO-1 reporting, subscribe to our blog, the PayParitySM Post, by clicking here.