The Equal Employment Opportunity Commission (EEOC) has 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. EEO-1 reports are currently required from private employers with 100 or more employees and certain federal contractors meeting applicable employee thresholds. Although the request has generated significant attention, it remains under review and does not change employers’ current reporting obligations.

Employers that are currently subject to EEO-1 reporting requirements must continue preparing to comply with existing reporting obligations. According to the EEOC’s official EEO Data Collections page, the 2024 EEO-1 Component 1 data collection is closed, and updates regarding the 2025 EEO-1 Component 1 data collection will be posted as they become available. Notably, last year’s collection period opened on May 20, 2025. The delay, coupled with the pending regulatory review request, is creating uncertainty regarding the timing and potential scope of ongoing EEO reporting requirements. 

What Does it Mean? 

In the short term, until the EEOC formally changes the regulations, employers should assume existing EEO-1 reporting requirements remain in effect and continue preparing accordingly. 

In the long term, if the EEOC ultimately rescinds EEO-1 reporting obligations, the change could significantly affect how workforce demographic data is collected and used by federal agencies and employers. EEO-1 data has historically been used by the EEOC to support enforcement of federal anti-discrimination laws and to analyze workforce demographics across industries. Many employers rely on EEO-1 data for internal pay equity reviews, diversity analytics, government contracting compliance, and broader workforce planning initiatives.  

While waiting for the opening of the 2025 data collection period, employers should continue focusing on several key compliance steps: 

• Confirm reporting eligibility to determine whether the organization meets current EEO-1 filing thresholds. 

• Review workforce demographic data to ensure employee race/ethnicity, sex, and job category information is accurate and up to date. 

• Audit HRIS and payroll systems to verify that required workforce data can be properly extracted and reported if the portal opens on short notice. 

• Continue monitoring EEOC announcements for updates regarding the 2025 EEO-1 Component 1 collection schedule and any changes to reporting requirements.