Large employers and certain government contractors are used to submitting equal employment opportunity data to the EEOC, as required by the applicable federal law. The 2022 reporting cycle is about to begin, with registration anticipated to open in April and data submissions due in May.
Depending on the state, some large employers may find themselves with state-specific reporting obligations.
For instance, employers with at least 100 employees (who also have at least 1 employee in California) are required to report payroll and demographic data to the California Department of Fair Employment and Housing (DFEH) by April 1, 2022. The state’s Pay Data Reporting Page has links to the Reporting Portal, user guide, and FAQs.
In addition, Illinois recently amended its Equal Pay Act to require private employers with more than 100 employees in Illinois to report detailed demographic and pay data and sign a compliance statement, among other administrative requirements. Although the Illinois Department of Labor (“ILDOL”) is supposed to send out notices and assign deadlines on a rolling basis, covered companies have the burden to comply, so it's important to keep close tabs on the timelines and an eye out for communications from the ILDOL regarding this issue.
The reporting landscape has changed in recent years so employers should continue to monitor developments in this area.
For more information about this topic, please contact the authors Jessica Shpall Rosen and Keli Liu, or your personal Greenwald Doherty attorney contact.
