EEOC Pay Data Rule: EEO-1 Data Update—Uncertainty Remains as to When Employers May Be Required To Submit EEO-1 Pay and Hour Data for 2018

Sullivan & Cromwell LLP - April 15, 2019
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On March 4, 2019, the Honorable Tanya S. Chutkan of the U.S. District Court for the District of Columbia vacated a decision by the Office of Management and Budget (the “OMB”) that had stayed a requirement adopted by the EEOC during the Obama administration that would have required employers to use a revised EEO-1 form to report pay data information by employee job position, gender, race and ethnicity (the so-called “Component 2 Data”). As a result of the ruling, the revised EEO-1 form is technically in effect.  (See our March 21, 2019 memorandum for further discussion of Judge Chutkan’s decision.)