EEO-1 Report

Who must file an EEO-1 report

Under federal regulations, two groups of employers must file:

• Private employers with 100 or more employees. Companies under common ownership or control that together reach 100 employees are also covered.
• Federal contractors and first-tier subcontractors with 50 or more employees that meet the contract threshold (generally a contract, subcontract or purchase order of $50,000 or more) or that act as depositories of government funds or issuing and paying agents for US savings bonds. This contractor rule came from regulations under Executive Order 11246, which was revoked in January 2025, so federal contractors below 100 employees should confirm against the current EEO-1 instruction booklet whether they still need to file.

State and local governments, public school systems and most educational institutions file different EEO reports instead. Employers with multiple locations file a consolidated report plus establishment-level reports. The EEOC administers the data collection, which is also used by the OFCCP for federal contractors.

What Component 1 includes

EEO-1 Component 1 is a headcount table. For each establishment, the employer reports the number of employees in each of 10 job categories, broken down by sex and by race or ethnicity.

The race and ethnicity categories are: Hispanic or Latino; and, for non-Hispanic employees, White, Black or African American, Native Hawaiian or Other Pacific Islander, Asian, American Indian or Alaska Native, and Two or More Races. Sex has historically been reported as male or female.

The snapshot comes from one pay period of the employer's choosing between October 1 and December 31 of the reporting year. Every full-time and part-time employee on the payroll in that period is counted, including temporary employees you pay directly. Workers supplied by a staffing agency are generally reported by the agency, not by the client.

A Component 2 pay and hours data collection ran for 2017 and 2018 data only and is no longer collected.

EEO-1 job categories

Every position must be mapped to one of these 10 categories, based on actual duties rather than job title:

1. Executive/Senior Level Officials and Managers
2. First/Mid-Level Officials and Managers
3. Professionals
4. Technicians
5. Sales Workers
6. Administrative Support Workers
7. Craft Workers
8. Operatives
9. Laborers and Helpers
10. Service Workers

Mapping is where most errors happen. Contact center agents usually fall under Administrative Support Workers, though sales-focused outbound agents may belong in Sales Workers. Team leads who direct the work of others and have real supervisory duties usually belong in First/Mid-Level Officials and Managers. Build the mapping once at the job-code level in your HRIS, document the reasoning, and review it whenever new job codes are created.

EEO-1 filing deadline

The EEOC sets the filing window each year and announces it in advance. In recent cycles the portal has opened in the spring and the deadline has fallen in late May or June for the prior year's data. There is no fixed date in the regulation, so check the EEOC's EEO-1 site each year rather than assuming last year's date.

Filing is done online through the EEOC's EEO-1 portal. The system runs automated checks and flags large year-over-year changes, which you may need to explain. Employers who fail to file can be compelled to do so by court order, and federal contractors can face compliance consequences.

How to collect EEO-1 data without bias

Race, ethnicity and sex data for the EEO-1 should come from voluntary employee self-identification. Most employers collect it during onboarding through a separate self-ID form, with a clear statement that providing it is voluntary and will not affect employment. The data must be kept separate from personnel decision making.

When an employee declines to self-identify, EEOC instructions have allowed employers to use employment records or observer identification for EEO-1 purposes. Many HR teams are uncomfortable with visual identification; the better fix is a well-explained self-ID form and an annual reminder to update it.

For applicants, self-ID data belongs in a separate process. Federal contractors use it for their affirmative action analysis and their applicant flow log.

Preparing the report: a practical routine

• In September, pick the snapshot pay period and lock it.
• Pull headcount by establishment, job code, sex and race or ethnicity from the HRIS.
• Check that every active job code maps to an EEO-1 category, and that remote employees are assigned to an establishment consistently.
• Look for missing self-ID data and chase it before the snapshot.
• Compare with last year's numbers by category and location, and write down explanations for big swings, such as a new site or a reorganization.
• File early in the window. The portal slows down near the deadline.

For a high-volume employer that hired heavily in Q4, the snapshot can look very different from the rest of the year. That is fine; just be able to explain it.

Common mistakes

• Mapping by title. A "Customer Success Manager" with no direct reports is not a manager for EEO-1 purposes.
• Counting agency temps. They usually belong on the staffing agency's report.
• Leaving remote workers off. Remote employees must be counted and assigned to an establishment.
• Not tracking subsidiaries. Common ownership can bring a group of small companies over the 100-employee threshold.

This is general information. Requirements can change year to year, so check the EEOC's current instruction booklet before filing.