After a three-year pause sine being halted in 2019, the Equal Employment Opportunity Commission (EEOC) plans to reinstate collection of pay data in EEO-1 Component 2 reports. Among its many roles, the EEOC enforces the Equal Pay Act of 1963, which requires equal pay for employees of all genders. In furtherance of this goal, the EEOC has used pay data gathered from employers’ EEO-1 Component 2 reports to assess the disparity in pay between employees of different genders. Despite halting pay data collection in 2019, the EEOC has used pay data collected through prior employer EEO-1 Component 2 reports to evaluate gender-based pay disparity, and recently released a comprehensive study examining pay data collected in 2017 and 2018.

EEOC Commissioner Keith Sonderling recently confirmed the planned return of EEO-1 Component 2 pay data reporting, stating “Watch out, it’s coming.” While the EEOC has not yet made a more official announcement of the pay data reporting requirement’s reinstatement, employers should be vigilant for a change in reporting requirements for future EEO-1 reports.