Important Pay Data Reporting Deadlines

*Important Update* EEOC opened the EEO-1 Reporting Portal on May 20, 2025. The deadline to file the 2024 EEO-1 Component 1 report is Tuesday, June 24, 2025. Employers can access updated instructions and information and get started here.

Springtime brings us allergies, nicer weather, and excitement about summer travel plans. It also represents pay data reporting season for large employers and federal contractors. Are you up to date with state and federal requirements?

California Pay Data Reporting

As a refresher, California law requires private employers of 100 or more employees and/or 100 or more workers hired through labor contractors to annually report pay, demographic, and other workforce data to the Civil Rights Department.

California’s reporting deadline is the second Wednesday of May each year. For 2024 data, the reporting deadline lands on May 14, 2025. Covered employers can learn more here. Note this is separate and in addition to the federal EEO-1 Component 1 data collection.

What is the EEO-1 Component 1 Data Collection?

Similar to California’s pay data reporting requirement, the EEO-1 Component 1 report is a mandatory annual data collection that requires all private sector employers with 100 or more employees to submit demographic workforce data, including data by race/ethnicity, sex, and job categories.

Federal contractors with 50 or more employees meeting certain criteria have also been required to file EEO-1 Component 1 reports.

• The revised instruction booklet continues to direct federal contractors with at least 50 (but fewer than 100) employees to file, without mention of President Trump’s January, 2025 revocation of EO 11246. EO 11246 is the Executive Order that created the obligation for federal contractors with fewer than 100 employees to file EEO-1 reports. With President Trump revoking that Order, it creates ambiguity as to whether this requirement is still in place. Contractors with fewer than 100 employees and questions about whether they are required to file should consult their counsel.

What Are the Revisions to the EEOC’s Instruction Booklet?

EEOC revised the instructions to eliminate the option to report non-binary employees. Employers will only be able to report employees as “male” or “female.” According to EEOC, this change is necessary to comply with President Trump’s Executive Order 14168, which states the federal government will recognize only two sexes—male and female.

Additionally, the EEOC will not send out “Failure to File” notices prior to the closing of the portal. It also included changes in the processing of undue hardship exemptions to reflect current regulations.

What Should Employers Do Now?

If you have 100 or more employees, and/or 100 or more workers hired through labor contractors, file as soon as possible with California’s Civil Rights Department, if you haven’t done so already. If you have 100 or more employees, or if you have 50 or more employees plus a federal contract that requires you to file the EEO-1 Component 1, make sure to submit by the June 24, 2025 deadline!

CEA members can call 800-399-5331 or email ceainfo@employers.org with additional questions.