Key Things to Know for the EEO-1 Component 2 Filing


What are the key things I should know about the EEO-1 Component 2 that I keep hearing about and how do I know if we’re required to file?


On July 1, 2019, the Equal Employment Opportunity Commission (EEOC) updated the Component 2 filing site with answers to frequently asked questions (FAQs) and other materials to assist filers with the submission of Component 2 data.   Still, it can get confusing, so the following are some important points to remember:


Employers must file 2017 and 2018 Component 2 compensation data by September 30, 2019.


Employers, including federal contractors, are required to submit Component 2 compensation data for 2017 if they have 100 or more employees during the 2017 workforce snapshot period.  Employers, including federal contractors, are required to submit Component 2 compensation data for 2018 if they have 100 or more employees during the 2018 workforce snapshot period.  Federal contractors with 50-99 employees are not required to report Component 2 compensation data.

  • Employers with workforces that fluctuated above and below the 100-employee threshold in October through December can choose a workforce snapshot period where the population fell below 100 employees and avoid the Component 2 filing requirement.


The workforce snapshot period is an employer-selected pay period between October 1 and December 31 of the reporting year. The only employees whose compensation and hours-worked data must be reported are full- and part-time employees who were on the employer’s payroll during the workforce snapshot period.  NOTE:  This snapshot period can be different than the period you selected for EEO-1 Component 1.

  • The workforce snapshot periods for reporting Component 2 data for 2017 and 2018 do not need to be the same.


To identify the compensation band in which to count an employee (only for the selected workforce snapshot period), use “Box 1 – Wages, tips, other compensation” of (IRS) Form W–2 as the measure of pay.  Employers may not use gross annual earnings instead of W-2 Box 1 earnings.


The Component 2 instructions adopt the Fair Labor Standards Act (FLSA) definition of “hours worked.” Therefore, the hours-worked data that employers report for the EEO-1 Component 2 will be based on the same hours worked that employers record for FLSA purposes. FLSA hours worked generally do not include paid leave, such as sick leave, vacation leave, or paid holidays.

  • For exempt employees, employers have the option to report the designated proxy hours of 40 or 20 hours per week for each week the employee workedthat year or, alternatively, to report actual hours worked, as defined by the FLSA, if the employer already maintains records of actual hours worked for that employee.


By now, you should have received your login letter from the EEOC, which has NEW login information (this is totally separate from your EEO-1 login information you used previously).  Employers can either enter data through their online filing system or by uploading a CSV file (this feature will be available by mid-August).

Contact or 877-324-6214 for available help.

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