What
Annual EEO-1 Component 1 report to the EEOC showing headcounts of employees by EEO job category, race/ethnicity, and sex, drawn from a single snapshot pay period in the fourth quarter of the report year.
Who
Private employers with 100 or more employees. Federal contractors with 50 or more employees and a federal contract or subcontract of $50,000 or more.
When
Choose any pay period between October 1 and December 31 as your workforce snapshot. File during the EEOC's announced collection window, which typically opens in the spring of the following year. There is no fixed statutory deadline; monitor the EEOC portal for the current year's dates.
Risk
Failure to file can result in EEOC-initiated court action to compel filing. Federal contractors face additional exposure, including potential contract cancellation, debarment, and OFCCP audit scrutiny. Submitting inaccurate data creates liability for false statements to the federal government.
100+
Private threshold
Private employers with 100+ employees file (federal contractors at 50+ with a $50k+ contract).
Oct-Dec
Snapshot period
Pick any one pay period in Q4 of the report year and use it consistently.
Spring
Filing window
The collection window typically opens in spring of the following year; monitor the EEOC portal.
| Item | Timing | Notes |
|---|---|---|
| Workforce snapshot period | Any pay period Oct 1 - Dec 31 of the report year | Choose one pay period and count all employees on payroll during that period. The same snapshot date should be used consistently for all establishments. |
| 2024 data filing window | May 20 - June 24, 2025, Closed | The 2024 EEO-1 Component 1 collection is closed. If you missed it, contact the EEOC directly. |
| 2025 data filing window | Not yet announced | Monitor eeoc.gov/data/eeo-data-collections for the opening date. Historically, the window opens in spring. |
| Amendments / corrections | During the open collection window | Corrections are permitted while the portal is open. Download your confirmation receipt immediately after certifying; the portal does not always allow re-access after the window closes. |
Item: Workforce snapshot period
Timing: Any pay period Oct 1 - Dec 31 of the report year
Notes: Choose one pay period; use the same snapshot date for all establishments.
Item: 2024 data filing window
Timing: May 20 - June 24, 2025 (Closed)
Notes: Collection is closed. If you missed it, contact the EEOC directly.
Item: 2025 data filing window
Timing: Not yet announced
Notes: Monitor eeoc.gov/data/eeo-data-collections; the window historically opens in spring.
Item: Amendments / corrections
Timing: During the open collection window
Notes: Download your confirmation receipt immediately after certifying.
- Company details: Legal name, EIN, NAICS code(s), headquarters address, and a complete list of all establishment names and addresses.
- Workforce headcounts: Number of employees on the snapshot date, broken down by EEO job category, race/ethnicity, and sex, separately for each establishment. See the EEO Job Category Reference section below for the 10 categories.
- Federal contractor status: Whether you hold a qualifying federal contract or subcontract of $50,000 or more, and the contract number if applicable.
- Organizational structure: Single vs. multi-establishment; any mergers, acquisitions, or spinoffs affecting the reporting entity during the report year.
- EEOC login credentials: Your Company ID and authorized filer contact. Update contacts annually so EEOC notices reach the right person.
1
Choose your snapshot pay periodAny pay period Oct 1 - Dec 31. Use the same date consistently across all establishments.
2
Categorize employeesInto the 10 EEO job categories based on job duties, not job titles. When in doubt, use the EEOC's job classification guide. See the reference table in the green section below.
3
Tally headcountsBy establishment, category, race/ethnicity, and sex. Confirm your payroll or HRIS system can generate this extract; don't manually count from a roster.
4
Log in to the EEOC's Online Filing System (OFS)Complete the headquarters report, individual establishment reports, and the consolidated company-level report. Large employers can upload a data file instead of entering data manually.
5
Review before certifyingCheck totals across establishments against your payroll extract. The consolidated total must match the sum of all establishment counts.
6
Certify and submitThen immediately download and save your confirmation receipt. Also save the underlying payroll extract and methodology notes used to generate the data.
- Filing system: All submissions go through the EEOC Online Filing System (OFS). There is no paper alternative.
- Entry options: Manual online entry per establishment, or bulk data file upload for multi-establishment filers. The EEOC publishes upload file specifications in the OFS help documentation.
- Certification: The report must be certified by an authorized official before submission is complete. An uncertified report is not considered filed.
- Account management: Keep your Company ID, authorized filer contacts, and establishment list current in the OFS. The EEOC sends collection notices to the address on file; if that contact has changed, you may not receive them.
- Submission confirmation receiptDownloaded from the OFS immediately after certification.
- Copies of all reports filedHeadquarters, each establishment, and the consolidated report.
- The payroll or HRIS extractUsed for the snapshot, showing the snapshot date and the headcount data.
- Categorization methodologyWhich job titles were mapped to which EEO categories, and why any judgment calls were made.
- Organizational change notesAcquisitions, spinoffs, establishment openings or closings during the report year and how they were handled in the filing.
Common traps
Categorizing by job title instead of job duties: EEO job categories are based on what an employee actually does, not what their title says. A "manager" whose primary duties are individual contributor work may belong in Professionals, not Officials and Managers. Use the EEOC's classification guide, not your org chart.
Not downloading the confirmation receipt immediately: The OFS does not always allow re-access after the collection window closes. Download your confirmation receipt the moment you certify; if you need to prove timely filing later, the receipt is your only evidence.
Misassigning remote employees: Remote workers should be assigned to the establishment they administratively report into, not the employer's headquarters by default, and not their home state. If a remote employee has no assigned establishment, assign them to the HQ establishment and note the methodology.
Assuming a low snapshot count avoids coverage: Coverage is based on whether you employ 100 or more people at any point, not only on your snapshot date. If you had 100+ employees at any time during the year and chose a slow week as your snapshot, you still must file.
FAQs
Who counts toward the 100-employee threshold?
All full-time and part-time employees on payroll count. Independent contractors do not. Temporary employees provided by a staffing agency are typically counted by the staffing agency, not by you, but confirm based on who controls the work.
Is this a federal or state requirement?
It is a federal requirement under Title VII and Executive Order 11246. Several states, including California and Illinois, have separate pay data reporting obligations with different data elements and deadlines. See Special Cases below.
What if we just became covered this year?
If you crossed the 100-employee threshold for the first time, you are required to file for that report year. Contact the EEOC to register your company in the OFS before the collection window opens.
Can we file a consolidated report instead of establishment-level reports?
No. If you have multiple establishments, you must file a headquarters report, an individual report for each establishment, and a consolidated company-level report. The consolidated report is generated automatically from the establishment data; it is not a substitute for establishment-level reporting.
- EEOC: EEO Data Collections (current collection status, coverage thresholds, and filing FAQs)
- EEO-1 Online Filing System (OFS) (filing portal and current collection window dates)
- DOL: OFCCP (federal contractor thresholds and enforcement)
- Multi-establishment employers: If you operate more than one physical location, you must file three types of reports: (1) a headquarters report for the main office, (2) an individual establishment report for each location with 50 or more employees, and (3) a consolidated company-wide report covering all employees. Establishments with fewer than 50 employees are included in the consolidated report only. The consolidated total must equal the sum of all individual establishment counts.
- Mergers and acquisitions: The EEOC provides specific guidance on which entity is responsible for filing in a transaction year. Generally, the surviving entity files for all employees as of the snapshot date, but the details depend on timing and structure. If you completed an acquisition or merger during the report year, review the EEOC's M&A instructions before filing and document your approach.
- Federal contractors (50+ employees, $50k+ contract): Covered contractors have a lower employee threshold than private employers (50 vs. 100) and face additional consequences for non-filing, including potential contract cancellation, debarment, and OFCCP compliance audits. Contractor status is determined by your contracts as of the snapshot date.
- California pay data reporting: California requires covered employers (100+ employees in CA, or 100+ employees with at least one CA employee) to file a separate Pay Data Report with the California Civil Rights Department each May. This report includes pay band and hours-worked data by race/ethnicity and sex, different from the EEO-1 headcount data. The federal EEO-1 filing does not satisfy California's requirement.
- Illinois pay data reporting: Illinois requires employers with 100+ employees and an Illinois business registration to submit EEO-1 data to the Illinois Department of Labor annually. Unlike California, Illinois currently accepts a copy of the federal EEO-1 filing, but verify current requirements with the IDOL each year, as the rules have evolved.
A plain-English guide to the 10 EEO job categories, the part of the filing that takes the most judgment. Categories are based on job duties, not job titles. When an employee's work spans categories, assign based on the majority of their actual duties.
| # | Category | Typical Roles | Key Distinction |
|---|---|---|---|
| 1 | Executive/Senior Level Officials & Managers | CEOs, Presidents, C-suite officers, Senior VPs | Highest levels of the organization; set broad policy; report to board or owner. Very few employees should fall here. |
| 2 | First/Mid Level Officials & Managers | Department managers, supervisors, team leads with direct reports | Directs work of others and has hiring/firing authority or significant input. Title alone doesn't qualify; must actually manage people. |
| 3 | Professionals | Accountants, engineers, HR specialists, attorneys, IT analysts, marketing professionals | Work requires specialized knowledge typically gained through a college degree or equivalent. Individual contributors in knowledge-work roles. |
| 4 | Technicians | Lab techs, medical techs, drafters, computer support specialists, licensed practical nurses | Apply technical knowledge in a practical, hands-on way, typically an associate degree or vocational training rather than a four-year degree. |
| 5 | Sales Workers | Sales reps, account executives, retail sales associates, insurance agents | Primary duty is selling, either directly to customers or in a business-to-business role. Includes both inside and outside sales. |
| 6 | Administrative Support Workers | Administrative assistants, receptionists, clerks, data entry staff, customer service reps | Office and clerical support roles. The largest category for most office-based employers. |
| 7 | Craft Workers | Electricians, plumbers, carpenters, machinists, mechanics, skilled tradespeople | Skilled manual trades, typically journeymen-level or higher. Requires significant training or apprenticeship. |
| 8 | Operatives | Assembly line workers, machine operators, drivers, production workers | Semi-skilled manual work, less specialized than Craft Workers but more trained than Laborers. Common in manufacturing and transportation. |
| 9 | Laborers & Helpers | General laborers, construction helpers, warehouse workers, freight handlers | Unskilled or low-skilled manual work; typically does not require prior training or specialized skills. |
| 10 | Service Workers | Food service workers, janitors, security guards, personal care aides, barbers | Service roles not elsewhere classified, distinct from Sales Workers (no selling) and Administrative Support (not office/clerical). Common in hospitality, healthcare support, and facilities. |
Source: EEOC EEO-1 Component 1 instructions. When a role is genuinely ambiguous, document your reasoning and apply it consistently across similar positions across all establishments.