AICPA Comments on EEOC Proposal to Include Additional Data on EEO-1 Form

The American Institute of CPAs (AICPA) has informed the Equal Employment Opportunity Commission (EEOC) of its concerns regarding the Commission’s February proposal to change its EEO-1 filing form with the intent of identifying possible trends in pay equity disparity among employers.  The EEO-1 form is mandatory for employers with 100 or more employees and is submitted in September of each year to the EEOC. 

The EEOC has proposed including W-2 wage and hours worked data, broken down by gender and race/ethnicity, on the EEO-1 form.  The EEOC’s proposed change would require employers to place wage and hours worked data into a chart among 10 broad job categories and 12 pay bands and does not differentiate among full-time versus part-time employees.   

In its March 31 letter to the EEOC, the AICPA outlined the diverse work the accounting profession is doing to promote inclusion and diversity in the profession, and expressed concerns about the burden that would be placed on employers who would have to submit the data, about the privacy of the data once submitted, and about the usefulness of the data to the EEOC given the use of broad job categories and pay bands. 

Following the EEOC’s review of the public comments, and any changes made by the EEOC based on the comments, the proposed changes to the form will be sent to the Office of Management and Budget (OMB) for additional review.   OMB will provide an additional 30 day comment period as part of its review process.  A final version of the form is expected to be released in the coming months.