EEO-1 and EEO-4 Filing Portal Proposed to open on May 20, 2025
Organizations waiting for the Equal Employment Opportunity Commission (EEOC) to provide updated information on the 2025 EEO-1 filing cycle—which requires employers to report 2024 data—may soon see progress, although the EEOC has not yet updated its official EEO-1 data collection website: https://www.eeocdata.org/eeo1.
The EEO-1 and EEO-4 Component 1 data collection site is being proposed by the EEOC to open May 20, 2025, with the deadline to submit and certify proposed for June 24, 2025. Final approved deadlines will be posted on the EEOC’s website.
The EEOC has also submitted a request to the Office of Management and Budget (OMB) seeking approval for what it describes as “non-substantive” revisions to the EEO-1 data collection process for the 2024 reporting cycle. The proposed changes affect the Instruction Booklet, not the data collection template itself. In the most recent OMB approval cycle, the EEO-1 form was updated to allow employers to voluntarily report employees who self-identify as “non-binary.” These individuals could be excluded from binary male/female headcounts and instead noted separately in a comment box.
However, under Executive Order 14168—“Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government”—the EEOC has now proposed removing the option to report non-binary employees separately, among other changes. The updated “Reporting by Sex” section in the revised Instruction Booklet has been significantly shortened and now reads: “The EEO-1 Component 1 data collection provides only binary options (i.e., male or female) for reporting employee counts by sex, job category, and race or ethnicity.”
As a reminder, private employers with 100 or more employees during an employer-selected pay period in the fourth quarter of the reporting year must submit and certify an annual EEO-1 Component 1 report. Additionally, federal contractors and subcontractors with 50 or more employees (and are not exempt from the provisions of these regulations in accordance with § 60-1.5; 24) and serve as a depository of Government funds in any amount or is a financial institution which is an issuing and paying agent for U.S. savings bonds and savings must file.
If your company utilizes a payroll provider, commercial accounting software or an HRIS system, the EEO-1 or EEO-4 data is likely available through a standard report/data download. If you would like assistance preparing your EEO-1 or EEO-4 Report, please contact us.
We will continue to monitor for any further guidance from the EEOC on reporting non-binary employees and potential filing requirements for small federal contractors. In the meantime, employers should begin preparing their required reports if they haven’t already done so.
Please reach out to the HR hotline at [email protected] or 866-474-6854 if you have any questions.
The information provided is not intended to be legal advice.