Pay Data Due by September 30th

Earlier this week, the Equal Employment Opportunity Commission (EEOC) announced its intent to collect employee pay data from qualifying employers as soon as September 30th.

The EEOC has said that this pay data would come from a single payroll run between October 1, 2018 and December 31, 2018.

According to the National Law Review, employers should:

  • Review any references to compensation in employee handbooks and revise any blanket prohibitions on employees disclosing their compensation to others.
  • Remind supervisors of employees’ limited right to ask their co-workers about compensation.
  • Train compensation decision-makers on equal pay law requirements, any compensation policies including revisions to the same, strategies and procedures for ensuring proper documentation of decision-making relative to compensation decisions, and the EEOC’s new pay data mandate.

The National Law Review reminds employers, however, that employers with 100 or more employers are still required to disclose their number of employees by sex, race, ethnicity, and job category by May 31st.

For more information and tips to prepare for this potential requirement, please click here.


The information included in this blog post originally appeared in an article from the National Law Review on April 5, 2019, written by Kelsey J. Schmidt and Gray I. Mateo-Harris of Barnes & Thornburg LLP.

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