The EEOC announced the opening of the 2024 EEO-1 Component 1 data collection on May 20, 2025, as anticipated in our previous legal alert on the topic. With the opening of the portal, covered employers are now able to submit their 2024 EEO-1 Reports. As a reminder, the filing deadline is June 24, 2025 – a much shorter window than years past.
Key Details to Note:
- The EEO-1 Report requires employers to submit workforce demographic data, including sex, race, ethnicity, and job categories, to help the EEOC monitor compliance with equal employment opportunity laws.
- Private employers with 100 or more employees are required to submit EEO-1 Reports. Based on the FAQs and Instruction Booklet released by the EEOC, it appears federal contractors who meet certain criteria with at least 50 employees continue to be required to file, even though this requirement is rooted in Executive Order 11246, which President Trump rescinded in January.
- Details regarding filing requirements and information, including the 2024 Instruction Booklet, can be found at www.eeocdata.org/eeo1.
Announcement from Acting Chair Andra Lucas:
The announcement from the EEOC includes a message from EEOC Acting Chair Andrea Lucas reminding employers of President Trump's Executive Order titled "Restoring Equality of Opportunity and Meritocracy," which deprioritizes the EEOC's enforcement of disparate impact discrimination cases, and announces that the EEOC will "prioritize remedying intentional discrimination claims."
Specifically, Acting Chair Lucas states:
"...under existing law, the fact that a neutral employment policy or practice has an unequal outcome on employees of a particular race or sex – that is, has a 'disparate impact' based on race or sex – does not justify your company or organization treating any of your employees differently based on their race or sex. As noted above, you must not use the information collected and reported in your organization's EEO-1 Component 1 report to justify treating employees differently based on their race, sex, or other protected characteristic."
Next Steps
Employers should start preparing their EEO-1 filings now to ensure they meet the June 24 deadline. If you need assistance determining whether your organization is required to file or need help with the submission process, the attorneys at FordHarrison are available to assist.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
