The Equal Employment Alternative Fee (EEOC) just lately introduced tentative plans to start accepting 2024 EEO-1 Studies from coated employers from Could 20, 2025, via June 24, 2025. EEO-1 reporting necessities apply to personal employers with no less than 100 staff and have traditionally coated federal contractors with no less than 50 staff and a federal contract value no less than $50,000. The report collects information on the race/ethnicity and gender make-up of the workforce. Usually, EEO-1 reviews are due by March 31 of every 12 months. As we beforehand reported, transitions in federal company governance brought on some uncertainty and delay. The EEOC has now submitted its 2024 EEO-1 Instruction Booklet to the White Home Workplace of Administration and Funds (OMB) for approval, together with proposed modifications to EEO-1 reporting as outlined in a doc entitled, “Justification for non-substantive modifications to EEO-1 Directions.”
The EEOC says the proposed modifications are meant to streamline effectivity and align EEO-1 reporting necessities with Government Order 14168, entitled “Defending Girls From Gender Ideology Extremism and Restoring Organic Reality to the Federal Authorities.” To adjust to the brand new coverage of utilizing solely “male” and “feminine” classifications in federal types, the EEOC proposes removing of the choice to report on staff who establish as non-binary. It stays unclear whether or not EEO-1 reporting will likely be required by federal contractors with no less than 50 U.S. staff in mild of the rescission of Government Order 11246, which we reported on earlier this 12 months. We count on additional clarification from the EEOC on whether or not this group of employers remains to be required to submit an EEO-1 Report. Additionally it is attainable that the EEOC’s anticipated schedule for information assortment is additional delayed on account of authorized challenges together with a number of pending lawsuits difficult Government Order 14168 and different “DEI-related” government orders.
Suggestions: We now await OMB approval and the EEOC’s directions and affirmation of the schedule for submitting EEO-1 Studies. We’ll proceed to observe federal litigation developments and company steering governing EEO-1 reporting obligations. Nevertheless, don’t rely on a delay or anticipate our subsequent publication for an replace. In case your group is probably a coated employer, we advocate periodically checking for bulletins on the EEO-1 Report web site. The timeline for reporting is extraordinarily quick as soon as the portal opens – solely 5 weeks. Have your information prepared and plan to submit your report(s) early in case you run into any technical points. We additionally advocate that you simply save copies and take screenshots of any affirmation messages so the corporate can show that it complied with submission necessities. In the event you take part in Vigilant’s Affirmative Motion Program (AAP), please contact your AAP consultant if you happen to want help, or name your Vigilant Regulation Group legal professional for particular recommendation.
