Quick Hits

• The 2024 EEO-1 data collection is set to open on May 20, 2025, and close at 11:00 p.m. (EDT) on June 24, 2025.
• The EEOC said the collection period will not extend beyond the deadline.
• There is a new instruction booklet for reporting for the 2024 cycle that removes the option to report employees as nonbinary.

Hard Deadline

The EEOC said there will be a “shorter collection period” for employers to file their 2024 reports, stating that the period will not extend beyond the “Published Due Date” deadline on June 24, 2025. The EEOC said that once the deadline “passes, no additional 2024 EEO-1 Component 1 report(s) will be accepted.”

Additionally, the EEOC said that all communications this filing cycle will be handled electronically, and no notifications will be sent via postal mail.

Unlawful Discrimination

In a separate statement, EEOC Acting Chair Andrea Lucas reminded employers of their obligations under Title VII of the Civil Rights Act of 1964 “not to take any employment actions based on, or motivated in whole or in part by, an employee’s race, sex, or other protected characteristics.” (Emphasis in original). The warning aligns with the Trump administration’s policy focus on eliminating diversity, equity, and inclusion (DEI) programs and its deemphasis of disparate impact liability.

Changes to Reporting

On May 12, 2025, the Office of Management and Budget (OMB) approved the EEOC’s 2024 EEO-1 Instruction Booklet, which included some key changes to reporting procedures. The new booklet eliminates the option to report nonbinary employees, allowing “only binary options (i.e., male or female) for reporting employee counts.”

Further, despite the rescission of Executive Order 11246, which mandated affirmative action programs in federal contracting, the new instruction booklet states that federal contractors with fifty or more employees are still required to file EEO-1 reports for the 2024 cycle.

Next Steps

EEOC regulations require that certain private employers with one hundred or more employees and federal contractors with fifty or more employees annually report the number of individuals they employ, broken down by job category and by sex and race or ethnicity. The data is collected electronically through the web-based “EEO-1 Component 1 Online Filing System (OFS).”

The EEOC has published a webpage with resources for employers, including frequently asked questions (FAQs), the 2024 instruction booklet, a user guide, and other resources.

Employers with EEO-1 reporting obligations may want to promptly begin preparing and submitting EEO-1 filings with particular consideration of the hard filing deadline.