Compliance Stuff

Window closes June 24 – and don’t expect an extension.   The Equal Employment Opportunity Commission  announced  the opening of the 2024 EEO-1 Component 1 data collection. Covered employers have until June 24, 2025, to submit their EEO-1 Reports. The announcement from the EEOC includes a message from Acting Chair Andrea Lucas. In addition to reminding employers of the general prohibition against discrimination based on protected characteristics, Ms. Lucas notes that President Trump’s Executive Order titled “ Restoring Equality of Opportunity and Meritocracy ” deprioritizes the EEOC’s enforcement of cases involving disparate impact discrimination. The disparate impact theory, which is codified in Title VII and other anti-discrimination statutes, provides that facially neutral policies can be discriminatory if they disproportionately affect individuals of a certain race or sex.  Instead, Ms. Lucas announced that under her leadership, the EEOC will “prioritize reme...

On April 15 th , 2025 , the  Equal Employment Opportunity Commission  (EEOC) submitted its proposed  2024 EEO-1 instruction booklet   via an  Information Collection Review  submitted to the Office of Information and Regulatory Affairs within the Office of Management and Budget.  If approved, organizations with 100 or more employees can begin filing their EEO-1 reports on May 20, 2025 . Reports must be filed on or before June 24, 2025. Changes in Requirements for Federal Contractors with Less Than 100 Employees As previously mentioned,  private  employers with 100 or more employees are required to file EEO-1 reports annually . Under Executive Order 11246, federal contractors with 50 or more employees were required to file the report, as well . However, the  rescission of Executive Order 11246  has  likely  removed this requirement, eliminating the need for federal contractors with less than 100 employees to submit EEO-1 re...