On June 4, 2026, Colorado Governor Jared Polis signed HB26-1207, requiring certain private employers conducting business in Colorado to submit demographic workforce data, commonly known as EEO-1 data, to the Colorado Secretary of State beginning July 1, 2027. The law applies to private-sector employers with 100 or more workers that were required to submit EEO-1 data to the EEOC as of March 1, 2026.  

Importantly, the law specifically requires reporting even if the federal government repeals or discontinues EEO-1 reporting requirements. The timing and the cavate are notable. 

As discussed here, the EEOC recently submitted a regulatory review request to the Office of Information and Regulatory Affairs (OIRA) that could eventually lead to the rescission of certain long-standing EEO data collection requirements, including EEO-1 reporting obligations. Colorado’s new law effectively creates a state-level reporting requirement that remains in place regardless of the outcome of those federal efforts.  

Key Takeaways to keep in mind:  

1. Colorado is creating its own EEO-1 reporting framework. Beginning July 1, 2027, covered employers must include EEO-1 demographic workforce data in periodic filings with the Colorado Secretary of State. 
2. Federal changes will not eliminate the Colorado reporting requirement. HB26-1207 expressly requires employers to provide the data even if the federal government repeals or discontinues EEO-1 reporting. 
3. The reporting standard is tied to the EEO-1 form as it existed on March 1, 2026. The law defines EEO-1 data as demographic workforce information categorized by race, ethnicity, gender, and job category using the federal form in effect on that date. 

What Does It Mean? 

While the EEOC has recently requested rescission and review of its EEO-1 reporting requirements, Colorado lawmakers have moved in the opposite direction by creating a state-level reporting obligation that remains in effect regardless of what happens at the federal level. 

Colorado is not alone. Since 2021, California employers have been subject to the state’s Pay Data Reporting requirements, which require covered employers to submit workforce demographic and compensation information to the California Civil Rights Department. More broadly, Colorado’s new reporting requirement illustrates how states are continuing to build and maintain their own workforce policy frameworks, often filling gaps left by changing federal priorities and enforcement approaches. 

To ensure compliance before the July 2027, effective date, employers should consider these next steps: 

• Confirm whether your organization meets the coverage threshold. 

• Continue collecting and maintaining EEO-1 workforce data. 

• Watch for updated guidance as implementation details and filing procedures are developed ahead of the July 2027 effective date.