According to published reports, US District Judge Tanya Chutkan issued a ruling from the bench today ordering employers to submit the pay data component of the EEO-1 form (“Component 2”) by September 30, 2019. In March, Judge Chutkan lifted the stay on collection of Component 2 data that had been imposed by the Office of Management and Budget. Until today, it was unclear when employers would have to submit the Component 2 data.

With today’s ruling, employers should begin the process of preparing for the September 30 submission. The process is new and quite technical and time required to prepare the submission should not be underestimated. Companies should consult with counsel to ensure that they are preparing the reports properly.