The Equal Employment Opportunity Commission (EEOC) has finally taken steps to move forward with the 2024 EEO-1 Component 1 data collection by submitting documents for approval with the White House Office of Management and Budget (OMB). As part of the EEOC’s submissions, a proposed new 2024 EEO Component 1 Instruction Booklet has been included that if accepted, will alter some employer reporting obligations. A summary of the EEOC’s proposals is set forth below.
Shortened Reporting Period
- The proposed 2024 Instruction Booklet provides for a shortened reporting period of five weeks, with the data collection platform opening on May 20, 2025, and closing on June 24, 2025. This means employers should start gathering their data now, to ensure they are prepared to file reports during the shortened period. Employers should continue to monitor developments as final opening and closing deadlines are expected to be published on theEEOC’s website. The HCM Service Team will continue to monitor any updates.
Reporting Requirements for Federal Contractors
- The EEOC’s proposed Instruction Booklet for 2024 EEO-1 reporting provides that federal contractors with 50 or more employees are still required to file EEO-1 reports for the 2024 cycle. The proposed guidance does not address the implications of President Trump’s Executive Order 14173 on these reporting obligations, so employers should continue to monitor developments as the OMB reviews the proposed materials and finalizes the reporting obligations.
Changes to Reporting by Sex
- Agency forms list only “male” or “female” for sex, as opposed to reporting based on gender identity. This proposal seeks to remove the voluntary reporting option for “non-binary” employees from the EEO-1 instructions. Employers will no longer have the option to submit non-binary employee data. For individuals who previously self-reported as “non-binary” during the 2024 reporting year, or if an employee refuses to self-identify with one of the two approved binary options, employers may need to perform a visual identification and provide their best response.
Action Items for Employers
Start gathering necessary employee data to prepare for the proposed data collection window of May 20th – June 24th, 2025
- 2. Adjust reporting practices for employee sex data, if needed
3. Have appropriate personnel trained on data collection and filing procedures.
4. Monitor regulatory updates for the finalized 2024 Instruction Booklet and reporting dates.
5. Consult with legal counsel regarding reporting obligations for federal contractor employers, if needed - Please visit our blog post regarding EEO-1 to access our guide on EEO processing.
