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For those of you at companies with 100 or more employees (either now or, if the company downsized, during the snapshot period of 2017 and 2018 which this EEO-1 filing covers) consider this your friendly myHRgenius HR Best Practices Tip that Component 2 data must be reported no later than September 30

In the event you need a refreshed memory on Component 2 data…. 

This is the new pay data component employers will need to report to provide the government (and employees and their legal counsel) with information regarding the company’s statistical wage practices and, mainly, whether there is any correlation between wages and race, ethnicity and/or gender.  This pay data will further break down into 12 pay bands, so employers will technically report which pay band each employee’s wages fall within and cover employees who worked for the company during the snapshot period.  For this year’s filing, the snapshot periods are Oct. 1, 2017 through Dec. 31, 2017, and Oct. 1, 2018 through Dec. 31, 2018.  The information will be absolute fodder for class action discrimination claims.  Employers will derive this data from W-2 information, which should be readily available.   

To perform the analysis and upload your data you will need to login to the EEOC portal – you should have received an email and letter with a reminder and login information.  In the portal you can upload the wage data and complete the filing.  Here’s the EEOC’s portal –

Additionally, as this is the first year for filing Component 2 data, the process has not been without confusion and difficulty for many employers.  There is a helpful FAQ, which is recommended to review –

If you are reading this and wondering what the Component 2 requirements are, or even what the EEO-1 report is and whether you need to file the report, you may find more information at, though it is likely the window to file will be closed by the time you look into the matter. Please contact any Labor and Employment attorney at Thompson Coe or myHRgenius at (651) 389-5000 or with any questions or to discuss.

Thompson Coe and myHRgenius Tip of the Week is not intended as a solicitation, does not constitute legal advice, and does not establish an attorney-client relationship.


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Kevin M. Mosher

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