Quick Hits

  • The EEOC announced on February 26, 2024, that the start date for the 2023 EEO-1 filing process would be April 30, 2024.
  • The deadline to file all 2023 EEO-1 reports is June 4, 2024.
  • The EEOC expects to post updated materials for the 2023 filings by March 19, 2024, and will open the EEO-1 help desk on April 30, 2024.

The announcement follows the recent closing of the 2022 EEO-1 filing platform on January 9, 2024.

The EEOC’s announcement follows closely on the heels of the completion of the 2022 EEO-1 filing cycle, which ended on January 9, 2024, when the filing platform was closed. The 2022 EEO-1 filing cycle opened on October 31, 2023, with a deadline of December 5, 2023, and a Failure to File absolute deadline of January 9, 2024. The 2022 EEO-1 filing cycle differed from prior years, as the filing platform opened considerably later in the year than prior filing cycles. With its latest announcement, the EEOC has moved the 2023 EEO-1 filing cycle closer to the May and June filing deadlines that were seen before the 2022 filing cycle.

The EEOC provided important details concerning support for these filings, stating that the EEO-1 online Filer Support Message Center, the new title for the filer help desk, would also open on April 30, 2024. The EEOC will post updated information concerning the 2023 EEO-1 data collection on the agency’s website as it becomes available. Specifically, the EEOC plans to post an updated 2023 EEO-1 Component 1 Instruction Booklet for filers and the updated 2023 EEO-1 Component 1 Data File Upload Specifications for filers by March 19, 2024. It is anticipated that the EEOC will release a new set of guidance in the form of answers to frequently asked questions (FAQs) for this year’s filings prior to the opening of the filing platform.

One very significant omission from this announcement was the lack of any discussion of adding pay data collection to the 2023 EEO-1 filings. While there had been much speculation that the EEOC would begin EEO-1 Component 2 pay data collection as part of the 2023 filings, there was no mention of this in the announcement, strongly suggesting that there will be no pay data collection for 2023.

EEO-1 filers now have a timetable for submitting their 2023 reports. This announcement maintains the tight time filing schedule that has been the norm for the last few filing cycles. EEO-1 filers may want to consider formulating a plan for gathering the data necessary to complete their 2023 EEO-1 reporting.

Ogletree Deakins’ OFCCP Compliance, Government Contracting, and Reporting Practice Group will continue to monitor developments and will provide updates on the Government Contractors and OFCCP Compliance, Government Contracting, and Reporting blogs as additional information becomes available.

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The experienced attorneys in our OFCCP Compliance, Government Contracting, and Reporting Practice Group advise and defend federal contractors and subcontractors on jurisdictional, compliance, and enforcement issues relevant to government contracting, including those involving the Office of Federal Contract Compliance Programs (OFCCP).

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