Nicole Rice

EEOC announces 2nd public comment period on Pay Data Collection Proposal

By Nicole Rice, Policy Director, Government Relations

Capitol Update, July 15, 2016

On July 14th, the U.S. Equal Employment Opportunity Commission (EEOC) opened its second public comment opportunity for the proposed changes to the EEO-1 pay data collection requirement for federal contractors. The 30-day comment period will end on Sunday, August 14th. The updated proposal, including the revisions made in response to the preceding comment period, can be found online at

The National Association of Manufacturers (NAM) has taken the lead on this federal proposal for the industry. NAM was one of over 300 entities to submit comments earlier this year, expressing “[full] support [for] pay equity and compliance with federal and state laws prohibiting sex-based wage discrimination …” but siting concerns that the proposal would “impose an unjustified burden on employers, result in the collection of unreliable information by the EEOC, fail to safeguard the confidentiality of the information, and will not further the Commission’s efforts to enforce Title VII of the Civil Rights Act or the Equal Pay Act.”

At the state level, CMTA has been active on recent attempts to incorporate similar reporting requirements into state law. Last year’s AB 1354 (Bill Dodd, D-Napa) sought to impose a reporting requirement that was duplicative of the information already included by contractors in California’s nondiscrimination program. That bill was initially opposed by CMTA and ultimately vetoed by the Governor Jerry Brown.

Assembly Member Dodd introduced a similar measure again this year in AB 1890 that seeks to compile data on gender wage inequity among state contractors and subcontractors as well as ensure they have policies for preventing unlawful discrimination. We continue to monitor discussions surrounding this effort.

You can find more information on the federal pay data collection proposal here.

Read more Labor & Employment articles

Capitol updates archive 989898989