On May 20, 2025, the US Equal Employment Opportunity Commission (EEOC) announced that the 2024 EEO-1 Component 1 data collection is now open, and eligible filers are required to file by the published due date of Tuesday, June 24, 2025. The EEOC has said that there will be no extension of the filing period.
EEO-1 Component 1 reports are a mandatory annual submission for all private-sector employers with 100 or more employees, and federal contractors with 50 or more employees meeting certain criteria. These reports require data on employees’ race, ethnicity, and sex, organized by job category.
In a message to filers, EEOC Acting Chair Andrea Lucas reminded organizations 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. She emphasized that demographic data collected and reported in EEO-1 Component 1 reports may not be used to facilitate unlawful employment discrimination. Title VII’s protections apply equally to all workers, and different treatment based on protected characteristics can constitute unlawful discrimination—regardless of which individuals are affected. There is no “diversity” exception to Title VII’s requirements.
To help employers understand the legal boundaries of diversity, equity, and inclusion (DEI)–related employment practices, the EEOC released a technical assistance Q&A titled, “What You Should Know About DEI-Related Discrimination at Work.” You can access it here.
Information and updates regarding the 2024 EEO-1 Component 1 reporting process, including the latest instruction booklet, are available here.
Compliance Perspective
Issue
The EEOC has opened the 2024 EEO-1 Component 1 data collection and reminded covered employers of their obligation to submit demographic workforce data by the June 24, 2025, deadline. Recent guidance emphasizes that while Title VII does not prohibit DEI initiatives, such efforts must be implemented in a way that does not result in employment decisions based on race, sex, or other protected characteristics. There is no “diversity exception” to Title VII, which prohibits discriminatory treatment regardless of intent.
Discussion Points
- Review your facility’s policies and procedures for collecting, using, and submitting EEO-1 Component 1 data. Ensure they are up to date and compliant with federal reporting requirements. If your facility engages in any DEI efforts, make sure that they are implemented in a manner that does not result in differential treatment based on protected characteristics.
- Train all staff involved in the data collection or submission process on how to accurately collect demographic data and properly complete the EEO-1 Report. Training should also include the limits of DEI-related actions under Title VII and emphasize that demographic data must not guide employment decisions.
- Conduct periodic audits to ensure that demographic data is being collected accurately, that EEO-1 Reports are submitted timely, and that the use of such data does not result in unlawful employment discrimination. Review DEI-related initiatives for potential compliance risks, and document corrective actions as needed.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*