The Equal Employment Opportunity Commission (EEOC) has initiated the 2024 EEO-1 Component 1 data collection process, requiring submissions by June 24, 2025. This annual requirement applies to private employers with at least 100 employees and certain federal contractors with 50 or more employees, as per Title VII of the Civil Rights Act of 1964.
This year, the EEOC has shortened the collection period as part of a “cost savings” effort. Employers who miss the deadline will be considered noncompliant. The agency also announced that all communications will now be electronic, eliminating postal notifications.
In line with President Donald Trump’s Executive Order 14168 from January 20, 2025, the optional reporting of nonbinary employee data has been removed. The EEO-1 Component 1 data collection now provides only binary options for reporting employee counts by sex.
Acting Chair Andrea Lucas reminded employers about compliance obligations under Title VII, which prohibits employment actions based on race, sex, or other protected characteristics. Lucas emphasized that different treatment based on these characteristics constitutes unlawful discrimination. She stated there is no “diversity” exception to Title VII’s requirements.
Additionally, the EEOC aligns with Trump’s April 23, 2025 executive order on “Restoring Equality of Opportunity and Meritocracy,” deprioritizing “disparate impact” enforcement. While disparate impact theory remains viable under federal and state law, the EEOC will focus on intentional discrimination claims.
Employers are advised to promptly review their demographic data and submit reports online within the designated timeframe. Queries regarding EEO-1 data collection should be directed to legal advisors such as Cooley LLP.
