As we shared with you in ouralert last August, Massachusetts recently enacted the Frances Perkins Workplace Equity Act, which requires employers with 25 or more employees in Massachusetts to provide pay ranges in all job postings, as well as to employees who request it and when employees are promoted or transferred. This requirement takes effect on October 29, 2025.
The law also requires large private employers – defined as those with 100 or more Massachusetts employees at any time in the prior calendar year – to submit their most recent EEO-1 report to the Massachusetts Secretary of State. The deadline to submit the EEO-1 report is February 1 of each year. If that date falls on a weekend or holiday, the deadline will be extended to the next business day. This year, the deadline is Monday, February 3, 2025. EEO-1 reports are annual workplace demographic reports required by the federal Equal Employment Opportunity Commission (EEOC) for private employers with 100 or more employees. The new Massachusetts law requires submission of the report most recently submitted to the EEOC the prior year; it does not require employers to prepare an updated EEO-1 report.
Notably, the EEO-1 report has not required pay data information (known as EEO-1 Component 2) since 2018. The Massachusetts Executive Office of Labor and Workforce Development has confirmed that covered employers only need to submit their most recently submitted EEO-1 reports, even if Component 2 is not part of those reports. If the EEOC begins requiring Component 2 in the future, it would become part of the required reporting to Massachusetts. The state has issued guidance on the new reporting requirements, which includes a link to the EEO-1 filing portal, availablehere.
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