On May 20, 2025, the U.S. Equal Employment Opportunity Commission (EEOC) announced the opening of the 2024 EEO-1 Component 1 data collection. Employers have until June 24, 2025, to submit their reports.
The EEO-1 Component 1 report is required for all private-sector employers with 100 or more employees, as well as federal contractors with 50 or more employees meeting certain criteria. These employers must submit workforce demographic data that includes information on the racial/ethnic and gender composition of their workforce by specific job categories, similar to California’s pay data reporting requirements.
The federal EEO-1 report is typically due every year on March 31, but the EEOC can move or extend the filing deadline at its discretion. This year’s filing window is later than usual because, as previously reported, the EEOC submitted documents to the White House Office of Management and Budget (OMB) for approval to modify the EEO-1 instructions and open the data collection.
The EEOC requested the OMB to approve non-substantive changes to the EEO-1 filing process to comply with Executive Order 14168, which ordered that all federal forms requiring an individual’s gender must not request gender identity. So, to comply, the EEO-1 data collection provides only binary options for recording an employee’s gender.
Notably, the EEO-1 data collection instruction booklet directs covered federal contractors to file the report, which is interesting because, as previously reported, Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” revoked the 60-year old Executive Order 11246, which was the basis for federal contractor affirmative action obligations.
Despite the revocation, the EEO-1 instruction booklet relies on Executive Order 11246 as the authority to require federal contractors to submit their EEO-1 reports and doesn’t mention the revocation of 11246. Covered federal contractors should review the EEOC’s materials, continue to monitor for additional updates and consult with legal counsel on their reporting requirements.
The EEOC electronically collects employers’ data through a web-based data collection application referred to as the EEO-1 Component 1 Online Filing System (OFS). Employers should review the 2024 EEO-1 Component 1 data collection resources on the EEOC’s website. These include the instruction booklet, fact sheets, FAQ documents and other information to assist employers in filing their reports.
According to the EEOC, the collection period will not extend beyond Tuesday, June 24, 2025. Additionally, all communications sent to filers will be electronic. No notifications about the 2024 collection will be sent to filers via postal mail.
James W. Ward, J.D., Employment Law Subject Matter Expert/Legal Writer and Editor, CalChamber
CalChamber members can read more about EEO Reporting Requirements in the HR Library. Not a member? See how CalChamber can help you.
