Client Alerts & Newsletters

Proposed Changes To EEO-1 Reporting Impact All Employers With 100 or More Employees


On November 16, 2005 the Equal Opportunity Employment Commission ("EEOC") voted to approve significant changes to the EEO-1 Report that all employers with 100 or more employees (and most government contractors with 50 or more employees) are required to submit on an annual basis. The long-awaited changes to the EEO-1 Report establish a multi-racial "two or more races" category, separate Asians from Pacific Islanders, and divide the "Officials and Managers" EEO-1 category into "Executive/Senior Level Officials and Managers" and "First/Mid-Level Officials and Managers."

The changes will likely require employers to re-survey their workforces to gather updated race/ethnicity information, and perhaps to reconfigure their data management systems to accurately collect and maintain the new data. As a result of the division of the Officials and Managers category into two categories, employers will also be required to revise their classification schemes for managerial employees. This change, driven in part by an Agency desire to better assess "glass ceiling" issues, is not simply administrative. Employers should systematically assess the jobs within their managerial ranks to make the appropriate classification decisions.

If approved by the OMB, as expected, the new EEO-1 Report will be effective for the 2007 reporting cycle.

For the EEOC press release announcing the changes see

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Rebecca L. Springer
Partner – Washington, D.C.
Phone: +1 202.624.2569

Kris D. Meade
Partner – Washington, D.C.
Phone: +1 202.624.2854

Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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