Proposed Elimination of EEO-1 Reporting Moves Forward

The U.S. Equal Employment Opportunity Commission (EEOC) may soon propose a significant change to federal workforce reporting requirements. The White House Office of Information and Regulatory Affairs (OIRA) has completed its review of the EEOC's draft proposal to rescind the annual Employer Information Report (EEO-1), clearing the way for the agency to publish the proposal for public comment.

At this time, the proposal has not been finalized and EEO-1 reporting requirements remain in effect. However, the EEOC has not yet opened the EEO-1 filing portal for the 2025 reporting year, creating uncertainty for covered employers that are preparing their annual workforce demographic reports.

Who Is Currently Required to File an EEO-1 Report?

Under existing regulations, EEO-1 reporting generally applies to:

Private-sector employers with 100 or more employees.
Federal contractors and first-tier subcontractors with 50 or more employees that hold a federal contract, subcontract, or purchase order of $50,000 or more.

Covered employers must annually report workforce demographic data by job category, race/ethnicity, and sex.

What Should Employers Do Now?

Although the EEOC may seek to eliminate the EEO-1 reporting requirement, no final action has been taken. Federal contractors should continue monitoring equal employment opportunity compliance obligations as other federal contractor requirements may remain in place regardless of any changes to EEO-1 reporting.