As we previously reported, the annual EEO-1 Reporting portal has opened and along with it some changes to the reporting requirements. Probably the most impactful change is the new requirement that companies may no longer file more than one EEO-1 report for the same address if the North American Industrial Classification System Code (NAICS) is the same for more than one of the entities. In other words, if your company has multiple entities at the same address and those entities, while legally distinct, engage in the same services, activities or product development you must now file a single consolidated report. For companies with complex organizational structures and/or significant acquisitions, this will require detailed review and assessment of your filings.
There is a mechanism for requesting a variance from this requirement, however the company will need to provide a basis to support the claim of an “undue hardship” which may require detailed company structure information to be submitted to the Commission for review.
In any respect, given all of the changes with this year’s reporting process and procedures, employers cannot wait to the last minute to prepare their reports and should be working to get them finalized now.