On April 29, 2019, the Equal Employment Opportunity Commission (EEOC) published a notice that the EEO-1 pay data collection is being reinstated immediately. According to the EEOC's website, employers covered by EEO-1 reporting requirements must submit 2018 Component 2 EEO-1 (pay and hours worked) data for their workforces by September 30, 2019. The notice comes as a result of an April 25, 2019, order by U.S. District Court for the District of Columbia Judge Tanya S. Chutkan.

The EEOC's announcement states that it "expects to begin collecting EEO-1 Component 2 data for calendar year 2018 in mid-July, 2019, and will notify filers of the precise date the survey will open as soon as it is available." The 2018 EEO-1 survey site officially opened on March 18, 2019, with a current deadline of May 31, 2019 to file EEO-1 Component 1 data from 2018.

Ogletree Deakins' Affirmative Action and OFCCP Compliance Practice Group will report on any further developments with regard to employers' reporting requirements on the firm's Affirmative Action/OFCCP blog.

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