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Has Your Company Reached 100 Employees?  Are you familiar with your EEO-1 Reporting Responsibilities?

The federal government has announced the EEO-1 reporting site has opened for the 2024 reporting cycle.  The reporting deadline is unusually short this year, with all reporting due by June 24, 2025.

What is this reporting, and who is required to do it?

Employers Required to Report

Companies with 100 employees for at least one week in fourth quarter of 2024, you are required to comply. Federal contractors and first tier subcontractors with 50 or more employees and who have at least $50,000 in contracts with the federal government annually are also required to comply.

When counting employees, each employee equals “1,” regardless of the number of hours they work.  Related companies in a control group arrangement are counted together when determining the 100 (or 50) employee threshold.

State and local governments, public elementary and secondary school districts, and local referral unions are generally exempt from EEO-1 reporting, though they may have other EEO data reporting obligations with the federal government.

We Have Never Filed – What Should We Do?

  1. If you have not already done so, collect demographic data on race and sex from all employees. Assure the employees this data is being collected to meet government obligations and that the information will not in any way affect their employment.  A sample form for collecting this data can be found here. For those employees who refuse to complete a form or who check the box, “I do not wish to disclose” on a form, you are allowed to make a “best guess” based on visual observation when reporting their race and sex.  Retain any forms or other documents used to collect this data in a file separate from personnel files for at least one year (3 years for federal contractors).
  2. Go to the EEO-1 website and register.  The reporting website can be found here: https://eeocdata.org/EEO1/home.  Beyond reporting, the website also contains FAQ’s to assist you with your reporting obligations.
  3. Select a week from the last quarter of 2024 as your reporting week.  This report is based on a “snapshot” week of the quarter.  The government does not dictate which specific week must be used.  Reporting should be based on the active employees as of that date only. 
  4. Sort employees in preparation for reporting: Employees are separated into 9 categories by the type of job.  Within those nine categories, employees must be subdivided into categories of race and sex.  Job categories and their descriptions can be found here (in Appendix C):
  5. Enter your data into the EEO-1 website by June 24, 2025. If you have multiple locations, you have report data based on three different groupings: (1) the main office/headquarters, (2) each additional location (“establishment report”), and (3) all locations and headquarters information combined (“consolidated report”).  If an employee has a job where they do not work at a location regularly or they work remotely from home, they are counted with the location to which they report.
  6. Implement data collection practices: Collect demographic information from all new hires going forward to simplify future reporting requirements. 
  7. Mark your calendars: Add a reminder to your calendar to check in January or early February 2026 for your next EEO-1 reporting deadline.  The reporting deadline in past years has been March 31 but was delayed in 2025.  It is likely that the June deadline will apply to 2025 only.

If you have any other questions, please contact your trusted OVD advisor.

The information and suggestions contained in this material have been developed from sources believed to be reliable. However, Olivier VanDyk Insurance Agency accepts no legal responsibility for correctness or completeness of this material, or its application to specific factual situations.


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