Judge Tanya S. Chutkan has ordered initial compliance with the EEO-1 pay data reporting obligation by September 30, 2019.

As we previously reported, the EEOC has informed the court it could complete collection of data by September 30th by utilizing the services of a third party vendor, though there would be quality and integrity concerns.  As proposed, the data collection would begin July 15th.

Plaintiffs had urged the court to require collection by May 31 – the deadline for filing of the current Component 1 portion of the form.

Questions remain around the reporting process, including instructions from EEOC about reporting logistics and other practical considerations – like whether it will be collecting 2017 and 2018 data or just 2018 data.  There is also the possibility of an appeal in the current litigation which may impact the reporting deadline.  But based on Judge Chutkan’s order today, however, employers will need to start working on complying with the reporting obligations for this year.

We will continue to analyze and interpret the written order and forthcoming information from EEOC and provide additional insights in the coming days.

Tags: EEO-1 Pay Data Reporting, EEOC, Equal Employment Opportunity Commission, Judge Tanya S. Chutkan, Pay discrimination
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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.

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