The Equal Employment Alternative Fee (EEOC) lately introduced tentative plans to start accepting 2024 EEO-1 Stories from coated employers from Might 20, 2025, by June 24, 2025. EEO-1 reporting necessities apply to personal employers with a minimum of 100 staff and have traditionally coated federal contractors with a minimum of 50 staff and a federal contract value a minimum of $50,000. The report collects knowledge 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 about some uncertainty and delay. The EEOC has now submitted its 2024 EEO-1 Instruction Booklet to the White Home Workplace of Administration and Price range (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 Govt 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 kinds, the EEOC proposes elimination of the choice to report on staff who determine as non-binary. It stays unclear whether or not EEO-1 reporting will likely be required by federal contractors with a minimum of 50 U.S. staff in mild of the rescission of Govt Order 11246, which we reported on earlier this 12 months. We anticipate additional clarification from the EEOC on whether or not this group of employers continues to be required to submit an EEO-1 Report. Additionally it is potential that the EEOC’s anticipated schedule for knowledge assortment is additional delayed on account of authorized challenges together with a number of pending lawsuits difficult Govt Order 14168 and different “DEI-related” govt orders.
Ideas: We now await OMB approval and the EEOC’s directions and affirmation of the schedule for submitting EEO-1 Stories. We are going to proceed to observe federal litigation developments and company steering governing EEO-1 reporting obligations. Nevertheless, don’t depend on a delay or await our subsequent publication for an replace. In case your group is doubtlessly a coated employer, we advocate periodically checking for bulletins on the EEO-1 Report web site. The timeline for reporting is extraordinarily brief as soon as the portal opens – solely 5 weeks. Have your knowledge prepared and plan to submit your report(s) early in case you run into any technical points. We additionally advocate that you just save copies and take screenshots of any affirmation messages so the corporate can show that it complied with submission necessities. If you happen to take part in Vigilant’s Affirmative Motion Program (AAP), please contact your AAP consultant when you want help, or name your Vigilant Legislation Group lawyer for particular recommendation.
