The EEOC last night published its much-anticipated file specifications for the 2017 and 2018 EEO-1 “Component 2” reports that must be filed with the Commission by September 30, 2019.

As expected, the file specifications will require employers to submit their 2017 and 2018 Component 2 pay and hours-worked data either by: (1) directly entering those data into an online form (available on July 15, 2019); or (2) by uploading a comma separated value (CSV) file through a secure file upload system (available in mid-August 2019). The new file specifications have been designed to “narrow” the width of these CSV files. According to the EEOC, this should help simplify the file production and uploading process.

Once the detailed establishment-specific pay and hours-worked data are submitted, employers will be required to use the EEOC’s online filing system to enter “employer-level” (or company-wide) information, such as responses to questions about the employer’s overall reporting status and information on the employer’s contact person and certifying official.

Given the number of establishments and records our member employers will be required to report, we expect that most CWC members will choose the CSV file upload option. We therefore recommend that the newly released file specifications be forwarded immediately to your human resources systems group for evaluation and processing. Once again, these Component 2 reports are due to the EEOC by September 30, 2019.

Our memo analyzing these file specifications and providing additional information on this year’s Component 2 reporting requirements will be published tomorrow, July 12, 2019. In the meantime, if you have any questions, please feel free to contact one of our compliance policy experts at 202-629-5650 or info@cwc.org.