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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

In 2016, the Equal Employment Opportunity Commission (EEOC) finalized a rule that would require employers submitting an annual EEO-1 Report to submit – in addition to the workforce race, national origin and sex data they historically provided – aggregate pay and hours worked data broken down by the various demographic categories. The first such data submission was set for the spring of 2018 (reporting 2017 data). However, shortly after President Trump took office, the Office of Management and Budget (OMB) placed a hold on the new reporting requirement.

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Several groups challenged the OMB’s actions, and in early March, a federal judge in Washington, D.C., lifted the hold and ordered the EEOC to begin collecting the data. With the 2018 EEO-1 reporting period currently under way, and with a May 31 deadline to submit their reports, the question remained: by when would employers have to submit the new pay and hours worked data? On April 25, the judge issued an order from the bench and set September 30, 2019, as the due date for 2018 data. The judge also ordered the EEOC to collect one additional year of data, but gave the EEOC the option of whether to require employers to submit data for 2017 (presumably by September 30) or 2019 (presumably early in 2020).

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The pay and hours reporting requirements will impose substantial additional burdens on employers required to file an EEO-1 Report. This includes government contractors with 50 or more employees and non-contractors with 100 or more employees. If your organization falls into one of those categories, we encourage you to promptly begin evaluating how you will collect and aggregate the data. Because the judge issued her order from the bench, additional information may become available when the written order is published. We will continue to monitor this issue and will provide additional guidance based on this information.

If you have questions regarding this order or any other labor and employment issue, please contact a member of Warner's Labor and Employment Practice Group.

Labor and Employment

Judge Orders EEOC to Begin Collecting EEO-1 Pay Data by September 30, 2019

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