This update is part of our continuing coverage of the EEO-1 pay data collection issue.

The EEOC had a choice between requiring employers to submit Component 2 pay data for CY 2017 by September 30, 2019 or for CY 2019 by Spring 2020, in addition to the CY 2018 pay data due on September 30, 2019.  The EEOC just announced that it will be collecting pay data for CY 2017.  The announcement on their website provides:

Notice of Immediate Reinstatement of Revised EEO-1:  Pay Data Collection for Calendar Years 2017 and 2018

EEO-1 filers should begin preparing to submit Component 2 data for calendar year 2017, in addition to data for calendar year 2018, by September 30, 2019, in light of the court's recent decision in National Women's Law Center, et al., v. Office of Management and Budget, et al., Civil Action No. 17-cv-2458 (D.D.C.).  The EEOC expects to begin collecting EEO-1 Component 2 data for calendar years 2017 and 2018 in mid-July, 2019, and will notify filers of the precise date the survey will open as soon as it is available.

Filers should continue to use the currently open EEO-1 portal to submit Component 1 data from 2018 by May 31, 2019.

We will continue to keep you updated on this developing matter.