EEO-1 Component 1 Instruction Booklet for OMB Review and Public Comment (May 2, 2023)

[SPECIFIC REPORTING YEAR WILL BE INSERTED BY EEOC] EEO-1 COMPONENT 1 Data Collection
OMB Control Number: 3046-0049
Instruction Booklet
Expiration Date: [TO BE INSERTED BY EEOC UPON APPROVAL BY OMB]

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
[SPECIFIC REPORTING YEAR WILL BE INSERTED BY EEOC] EEO-1
COMPONENT 1
DATA COLLECTION
Employer Information Report – Standard Form 100
EEO-1 Component 1 Report
INSTRUCTION BOOKLET
NOTICE
As discussed in the 30-day Notice published in the Federal Register on May 2,
2023, the EEOC created the Office of Enterprise Data and Analytics (OEDA) in
May 2018 with the goal of creating a modern data and analytics organization at
the agency. Since its creation, OEDA, which administers the agency’s EEO data
collections, including the EEO-1 Component 1, has worked to modernize the
collections and improve the quality of data collected. OEDA has also streamlined
functions, such as providing additional self-service options, resource materials,
and an online support message center.
As part of its ongoing modernization efforts and in response to feedback from
filers in prior collections, OEDA has redesigned the EEO-1 Component 1
Instruction Booklet to better meet the needs of filers. The Instruction Booklet
consolidates existing filer-support materials, including frequently asked questions
(FAQs) and fact sheets, into a single resource for filers and provides additional
information to clarify reporting requirements. Like the dedicated EEO-1
Component 1 website launched by the EEOC in 2021, the updated Instruction
Booklet will serve as a “one-stop-shop” containing important information for new
and returning filers.
OVERVIEW OF THE EEO-1 COMPONENT 1 REPORT
Since 1966, the EEOC has required employers to submit workforce demographic data (EEO-1
Component 1) on an annual basis. All private employers that are covered by Title VII of the Civil
Rights Act of 1964, as amended (Title VII), 1 and that have 100 or more employees are required to
file workforce demographic data. 2 In addition, U.S. Department of Labor, Office of Federal
Contract Compliance Programs (OFCCP) regulations require certain federal contractors to file the
EEO-1 Component 1 if they have 50 or more employees and are not exempt as provided for by 41
42 U.S.C. 2000e, et seq.
The EEOC’s EEO-1 regulation is at 29 CFR Part 1602 Subpart B. § 1602.7 requires eligible employers to file “…in conformity
with the directions set forth in the form and accompanying instructions.”

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CFR 60-1.5. 3
Under these authorities, private employers with 100 or more employees and federal contractors
with 50 or more employees and that meet certain criteria are required to report annually the number
of individuals they employ by job category 4 and by sex and race or ethnicity. 5 These data are
currently collected electronically by the EEOC through a web-based data collection application
(i.e., portal) referred to as the EEO-1 Component 1 Online Filing System (OFS). 6 Employers must
submit their data electronically to the OFS through either manual data entry or the upload of a data
file. The individual EEO-1 reports are confidential. 7 EEO-1 data are used by the EEOC to
investigate charges of employment discrimination against employers in private industry and to
publish periodic reports on workforce demographics. 8
3 Pursuant to Executive Order 11246, OFCCP in 1978 issued its regulations describing the EEO-1 as a report “promulgated jointly
with” the EEOC and requiring certain contractors to submit “complete and accurate reports” annually. 41 CFR 60-1.7(a). OFCCP
obtains EEO-1 Component 1 reports for federal contractors and subcontractors (contractors) pursuant to its own legal authority
under E.O. 11246 and its implementing regulations. See id at 60-1.7(a)(1).
4
The 10 job categories are: Executive/Senior Level Officials and Managers; First/Mid-Level Officials and Managers;
Professionals; Technicians; Sales Workers; Administrative Support Workers; Craft Workers; Operatives; Laborers and Helpers;
and Service Workers.
5
The EEO-1 Component 1 uses federal race and ethnicity categories, which were adopted by the Commission in 2005 and
implemented in 2007. The seven race/ethnicity categories are: Hispanic or Latino – A person of Cuban, Mexican, Puerto Rican,
South or Central American, or other Spanish culture or origin regardless of race. White (Not Hispanic or Latino) – A person having
origins in any of the original peoples of Europe, the Middle East, or North Africa. Black or African American (Not Hispanic or
Latino) – A person having origins in any of the black racial groups of Africa. Native Hawaiian or Other Pacific Islander (Not
Hispanic or Latino) – A person having origins in any of the peoples of Hawaii, Guam, Samoa, or other Pacific Islands. Asian (Not
Hispanic or Latino) – A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian
Subcontinent, including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand,
and Vietnam. American Indian or Alaska Native (Not Hispanic or Latino) – A person having origins in any of the original peoples
of North and South America (including Central America), and who maintain tribal affiliation or community attachment. Two or
More Races (Not Hispanic or Latino) – All persons who identify with more than one of the above five races. Please see Appendix
B of the Instruction Booklet for additional information on the EEO-1 Component 1 race and ethnicity categories.
6 EEO-1 Component 1 filers may access the EEO-1 Component 1 Online Filing System (OFS) through the EEOC’s dedicated EEO1 Component 1 website at www.eeocdata.org/eeo1.
7 All reports and any information from individual reports are subject to the confidentiality provisions of Section 709(e) of Title VII
of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-8(e), as amended (Title VII) and may not be made public by the EEOC prior to
the institution of any proceeding under Title VII involving such information. Any EEOC employee who violates this prohibition
may be found guilty of a criminal misdemeanor and could be fined or imprisoned. The confidentiality requirements allow the EEOC
to publish only aggregated data, and only in a manner that does not identify any particular filer or reveal any individual employee’s
personal information. Because OFCCP obtains EEO-1 data for contractors under its own E.O. 11246 authority, some courts have
ruled that the Title VII prohibition against disclosure does not apply to OFCCP’s collection of EEO-1 data. See, e.g., United Techs.
Corp. v. Marshall, 464 F. Supp. 845, 851-52 (D. Conn. 1979); Sears Roebuck & Co. v. Gen. Servs. Admin., 509 F.2d 527, 529
(D.C. Cir. 1974). Accordingly, the EEO-1 Component 1 data of federal contractors received by OFCCP may be subject to potential
disclosure by OFCCP under the Freedom of Information Act (FOIA), although FOIA exemptions may prevent disclosure. For more
information, see the Department of Labor’s FOIA regulations at 41 CFR part 70 and frequently asked questions (Freedom of
Information Act (FOIA) Frequently Asked Questions | U.S. Department of Labor (dol.gov)) at https://www.dol.gov/agencies/ofccp/
faqs/foia. With respect to other federal agencies with a legitimate law enforcement purpose but without OFCCP’s independent
authority to collect EEO-1 data, the EEOC gives access to information collected under Title VII only if the agencies agree, by letter
or memorandum of understanding, to comply with the confidentiality provisions of Title VII. In addition, section 709(d) (42 U.S.C.
2000e-8(d)) provides that the EEOC shall furnish upon request and without cost to state or local civil rights agencies information
about employers in their jurisdiction on the condition that they not make it public prior to starting a proceeding under state or local
law involving such information. The EEOC shares EEO-1 data with Fair Employment Practices Agencies (FEPAs) pursuant to
Worksharing Agreements that impose obligations on the contracted FEPA with respect to confidentiality, privacy, and data security.
On a case-by-case basis, the EEOC may share EEO-1 data with a FEPA that does not have a Worksharing Agreement, but only if
that FEPA agrees to comply with confidentiality, privacy, and data security obligations similar to those imposed on FEPAs with
Worksharing Agreements.
8 Any reports the EEOC publishes based on EEO-1 Component 1 data include only aggregated EEO-1 Component 1 data that
protect the confidentiality of each employer’s information, as well as the privacy of each employee’s personal information.

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INSTRUCTIONS
1. LEGAL BASIS
All private employers and federal contractors meeting the eligibility requirements detailed below
have a mandatory legal obligation to submit and certify annual EEO-1 Component 1 report(s)
containing required workforce demographic data to the EEOC. 9 The instructions for submitting
and certifying such reports, including the types of data requested and relevant deadlines, are
provided here in the [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC] EEO-1 Component 1 Instruction Booklet. 10
2. WHO MUST FILE
Pursuant to Title VII and Executive Order Number 11246, private employers and federal
contractors meeting the below requirements have a mandatory legal obligation to submit and
certify annual EEO-1 Component 1 report(s) containing required workforce demographic data to
the EEOC. 11 Different employee threshold requirements apply depending on whether the employer
is a federal contractor that meets certain criteria.
Please note the EEOC does not collect workforce demographic data from local referral unions,
state and local governments, and public elementary and secondary school systems and districts
through the EEO-1 Component 1 data collection. Demographic data for these entities are collected
through other EEO data collections administered by the EEOC. 12 These biennial data collections
include the EEO-3 Local Union Report, the EEO-4 State and Local Government Report, and the
EEO-5 Elementary-Secondary Staff Information Report. 13

9 The authorities under which EEO-1 Component 1 data are collected include: Section 709(c) of Title VII and Sections 1602.71602.14, Chapter XIV, Title 29 of the Code of Federal Regulations (CFR); Exec. Order No. 11246, 30 FR 12319 (Sept. 24, 1965)
and 40 CFR 60-1.7(a).
10 To further assist filers, the EEOC provides supplementary resource materials (e.g., user’s guide; frequently asked questions
(FAQs); fact sheets; mini help desk guides; video tutorials) at the opening of each data collection. Access by registered OFS account
holders to these supplementary resource materials is available through the dedicated EEO-1 Component 1 data collection website
at www.eeocdata.org/eeo1.
11
An employer that receives an EEO-1 Component 1 filing notice from the EEOC but believes it is not required to file must access
the EEO-1 Component 1 Online Filing System (OFS) to complete the embedded eligibility screener. If the screener confirms
eligibility, the employer must follow the prompts to submit and certify the required workforce demographic data. If the eligibility
screener indicates the employer is ineligible to file, the employer must certify that it is ineligible in the OFS. Failure to certify
ineligibility through the OFS will result in future EEO-1 Component 1 filing notices being sent to the employer by the EEOC.
Additionally, an employer that receives an EEO-1 Component 1 filing notice from the EEOC but has ceased operations and is no
longer in business must also access the EEO-1 Component 1 Online Filing System (OFS) to complete the eligibility screener. If the
eligibility screener indicates the employer is ineligible to file, the employer must certify that its company is ineligible and no longer
in business in the OFS. Similarly, failure to certify ineligibility through the OFS will result in future EEO-1 Component 1 filing
notices being sent to the employer by the EEOC.
12 If you are one of these entities but have received an EEO-1 Component 1 filing notice from the EEOC, please contact the EEO1 Component 1 Filer Support Team via the Message Center at www.eeocdata.org/eeo1.
13 Please note that the National Center for Education Statistics (NCES), located within the U.S. Department of Education’s Institute
for Education Sciences, collects data on post-secondary education through the annual Integrated Postsecondary Education Data
System (IPEDS) Survey. See https://nces.ed.gov/ipeds/.

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Private Employers 14
A private employer that is subject to Title VII and that has 100 or more employees at any time
during the fourth quarter (i.e., October 1 through December 31) of the reporting year 15 has a
mandatory legal obligation to submit and certify an annual EEO-1 Component 1 report containing
required workforce demographic data to the EEOC. 16
Additionally, a private employer that is subject to Title VII with fewer than 100 employees has a
mandatory legal obligation to submit and certify an annual EEO-1 Component 1 report containing
required workforce demographic data to the EEOC if the employer owns, is owned by, and/or is
affiliated or associated 17 with another employer or there is centralized or common ownership,
control, 18 or management so that the group of employers constitutes a single enterprise and/or
integrated enterprise and the entire enterprise had 100 or more employees 19 at any time during the
fourth quarter (i.e., October 1 through December 31) of the reporting year. 20
Federal Contractors
Pursuant to Executive Order 11246 and Office of Federal Contract Compliance Programs
(OFCCP) regulations, 21 a federal prime or subcontractor that meets all the following four criteria 22
has a mandatory legal obligation to submit and certify annual EEO-1 Component 1 report(s)
containing required workforce demographic data to the EEOC. The four criteria outlined in the
OFCCP regulations 23 require a contractor to file the EEO-1 if it:
(1) is not exempt from the provisions of these regulations in accordance with § 60-1.5; 24

14
Appendix A of the Instruction Booklet provides the definition of an “employer” for purposes of filing the EEO-1 Component 1
report(s).
15 Workforce demographic data (i.e., employee data by job category and sex and race or ethnicity) submitted by an eligible employer
must include all full-time and part-time employees who were employed during an employer-selected pay period (i.e., “workforce
snapshot period”) in the fourth quarter (i.e., October 1 through December 31) of the reporting year. Please refer to the below section
of the Instruction Booklet entitled “WORKFORCE SNAPSHOT PERIOD” for additional information.
16 Beginning with the 2023 EEO-1 Component 1 data collection, tentatively scheduled to open in 2024, an employer that meets the
employee threshold for EEO-1 Component 1 reporting purposes at any time during the fourth quarter (i.e., October 1 through
December 31) of the reporting year, may not select a “workforce snapshot period” from this quarter where it falls below the
threshold in an effort to avoid the filing requirement.
17 For example, if there is interrelation between operations.
18 For example, there is financial control or centralized control of personnel policies and/or labor relations.
19
For example, if an employer (e.g., a parent corporation) has only 30 employees but owns two separate subsidiaries (i.e.,
establishments) each with 35 employees, the headquarters of the parent corporation must file EEO-1 Component 1 reports for its
two subsidiaries (i.e., establishments) since the parent corporation and its two subsidiaries comprise a single enterprise with 100
employees.
20 Workforce demographic data (i.e., employee data by job category and sex and race or ethnicity) submitted by an eligible employer
must include all full-time and part-time employees who were employed during an employer-selected pay period (i.e., “workforce
snapshot period”) in the fourth quarter (i.e., October 1 through December 31) of the reporting year. Please refer to the below section
of the Instruction Booklet entitled “WORKFORCE SNAPSHOT PERIOD” for additional information. Also, beginning with the
2023 EEO-1 Component 1 data collection, tentatively scheduled to open in 2024, an employer that meets the employee threshold
for EEO-1 Component 1 reporting purposes at any time during the fourth quarter (i.e., October 1 through December 31) of the
reporting year, may not select a “workforce snapshot period” from this quarter where it falls below the threshold in an effort to
avoid the filing requirement.
21
41 CFR 60-1.7(a). See https://www.ecfr.gov/current/title-41/subtitle-B/chapter-60/part-60-1/subpart-A/section-60-1.7.
22 Id.
23 Id.
24 41 CFR 60-1.5. See https://www.ecfr.gov/current/title-41/subtitle-B/chapter-60/part-60-1/subpart-A/section-60-1.5.

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(2) has 50 or more employees;
(3) is a prime contractor or first tier subcontractor; and
(4) has a contract, subcontract or purchase order amounting to $50,000 or more or serves
as a depository of Government funds in any amount, or is a financial institution which
is an issuing and paying agent for U.S. savings bonds and savings notes: Provided, That
any subcontractor below the first tier which performs construction work at the site of
construction shall be required to file such a report if it meets requirements of (1), (2)
and (4).
Filers with questions as to whether an employer (i.e., company) is a federal prime or subcontractor
meeting the above criteria should refer to OFCCP’s regulations at https://www.ecfr.gov/current/
title-41/subtitle-B/chapter-60/part-60-1/subpart-A/section-60-1.7. Additional information on
federal contractor status may also be found on OFCCP’s website at https://www.dol.gov/agencies/
ofccp or by contacting OFCCP directly at https://www.dol.gov/agencies/ofccp/contact.
3. WHEN TO FILE
The [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE
INSERTED BY EEOC] EEO-1 Component 1 data collection is scheduled to open on [SPECIFIC
DATE FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]. The deadline to
file the [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE
INSERTED BY EEOC] EEO-1 Component 1 report(s) is [SPECIFIC DATE FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC]. The final opening and deadline dates
will be posted on the EEOC’s dedicated website for its EEO-1 Component 1 data collection at
www.eeocdata.org/eeo1 and on the EEOC’s public website at www.eeoc.gov. Filers are strongly
advised to visit www.eeocdata.org/eeo1 for the latest updates regarding the [SPECIFIC
REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]
EEO-1 Component 1 data collection, including any updates regarding the deadline to submit and
certify reports. Once data collection closes for a particular reporting cycle, employers are not able
to correct and/or update any demographic workforce data reported during that cycle.
Further, an employer that fails to submit required EEO-1 Component 1 report(s) during any
reporting cycle(s) is not permitted to submit any such reports during subsequent reporting cycle(s).
For example, an eligible employer that failed to submit a 2021 EEO-1 Component 1 report(s) is
not permitted submit that report during the 2022 EEO-1 Component 1 data collection cycle.
4.

HOW TO FILE

The EEOC requires electronic submission of EEO-1 Component 1 report(s) through a web-based
data collection application (i.e., portal) referred to as the EEO-1 Component 1 Online Filing System
(OFS). The OFS is accessible at www.eeocdata.org/eeo1.
All individuals responsible for filing an employer’s reports will be required to have an individual
user account associated with their email address to access the EEO-1 Component 1 Online Filing
System (OFS). To create a new account, visit www.eeocdata.org/eeo1/signin and select “Create an
Account.” New account holders for employers (i.e., companies) that have filed in prior year
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reporting cycles can link their individual user account to the employer record using the employer’s
“OFS Company ID” and “Employer PIN,” which will be sent to them via postal mail prior to the
opening of data collection. Account holders for employers that have never filed before can register
a new employer by selecting “Add Employer” on the “My Employer List Screen.” Returning OFS
account holders who created their account during or after the 2019/2020 data collection cycle, can
sign in using their existing username (i.e., email address) and password. Returning account holders
may be required to reset their password when logging in to the OFS if the account holder has not
accessed the OFS in the past 90 days. Account holders must submit the employer’s workforce
demographic data electronically in the web-based portal (i.e., OFS) through either (1) manual data
entry 25 or (2) data file upload. 26 The employer’s certifying official must then certify the EEO-1
Component 1 report(s) in the OFS.
The EEOC will only accept EEO-1 Component 1 report(s) submitted and certified through the
agency’s OFS. The EEOC will not accept reports submitted via paper or through other non-OFS
electronic means (e.g., email, CD-ROM). The EEOC will consider filers submitting reports outside
of the OFS to be non-compliant for purposes of their mandatory EEO-1 Component 1 filing
obligation.
5. WHAT IS AN ESTABLISHMENT
An establishment is generally a single physical location where business is conducted or where
services or industrial operations are performed (e.g., factory, mill, store, hotel, movie theater, mine,
farm, airline terminal, sales office, warehouse, or central administrative office). 27 Establishments
at different physical locations must be reported as separate establishments even if conducting the
same business or performing the same services or industrial operations. In addition, employers
should only include establishments located in the 50 United States and the District of Columbia. 28
6. REQUIRED REPORT FOR A SINGLE-ESTABLISHMENT EMPLOYER
The EEOC defines a single-establishment employer as an employer with a single establishment
where business is conducted or where services or industrial operations are performed. A singleestablishment employer is also referred to as a single-establishment filer for purposes of the EEO1 Component 1 data collection. A single-establishment employer is required to submit and certify
only one EEO-1 Component 1 Report (i.e., a “Single-Establishment Employer Report”).

The “manual data entry” option requires directly entering workforce demographic data into the EEOC’s web-based data
collection application referred to as the EEO-1 Component 1 Online Filing System (OFS).
26 The “data file upload” option requires uploading a data file using the EEOC’s approved [SPECIFIC REPORTING YEAR FOR
EACH DATA COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 Data File Upload Specifications.
27 See Frequently Asked Question 2 (What is an establishment?) at https://www.census.gov/naics/ for the U.S. Census Bureau’s
North American Industry Classification System (NAICS) definition.
28 Employers should not include establishments located in Puerto Rico, the Virgin Islands, or other American protectorates.
However, foreign-based and/or foreign-owned employers must report for eligible establishments located in the 50 United States
and the District of Columbia. If a foreign-based and/or foreign-owned employer has a United States-based headquarters, the U.S.
based headquarters is responsible for filing as a multi-establishment filer (i.e., multi-establishment employer) for all the employer’s
establishments located in the 50 United States and the District of Columbia. If a foreign-based and/or foreign-owned employer
does not have a headquarters based in the 50 United States or the District of Columbia, one of its establishments located in the U.S.
may file on behalf of all the employer’s establishments as a multi-establishment filer (i.e., multi-establishment employer) but is not
required to do so. Otherwise, each establishment must file its own EEO-1 Component 1 report with the EEOC.
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Single-Establishment Employer Report 29
An employer conducting business or performing services or industrial operations at only one
establishment is required to submit and certify one EEO-1 Component 1 report. This report is
referred to as a “Single-Establishment Employer Report.” The “Single-Establishment Employer
Report” must include demographic data for all the employer’s employees categorized by job
category and sex and race or ethnicity.
7. REQUIRED REPORTS FOR A MULTI-ESTABLISHMENT EMPLOYER
The EEOC defines a multi-establishment employer as an employer with more than one
establishment where business is conducted or where services or industrial operations are
performed. A multi-establishment employer is also referred to as a multi-establishment filer for
purposes of the EEO-1 Component 1 data collection. A multi-establishment employer is required
to submit and certify all the following three types of EEO-1 Component 1 reports (i.e.,
“Consolidated Report,” “Headquarters Report,” Establishment-Level Report(s)”). 30
Headquarters Report 31
A multi-establishment employer is required to submit and certify a “Headquarters Report.” The
“Headquarters Report” must include demographic data for all the employer’s employees at its
headquarters (i.e., main office site), as well as any remote employees who report to the employer’s
headquarters, categorized by job category and sex and race or ethnicity. 32
Establishment-Level Report 33
A multi-establishment employer is required to submit and certify an “Establishment-Level Report”
for each non-headquarters establishment of the employer regardless of the number of employees
at the establishment. The “Establishment-Level Report” must include demographic data for all the
employer’s employees at each establishment, as well as any remote employees who report to the
establishment, categorized by job category and sex and race or ethnicity. 34
29 The “Single-Establishment Employer Report” was formerly referred to as a “Type 1” single establishment report. Beginning
with the 2022 EEO-1 Component 1 data collection, this report is now known as a “Single-Establishment Employer Report.”
30 Multi-establishment employers, including, for example, parent corporations and their subsidiary holdings, must report
demographic workforce data for all employees at each establishment and subsidiary establishment(s). A multi-establishment
employer is not permitted to report its entire workforce on the employer’s “Headquarters Report.” Workforce demographic data
for non-headquarters establishments must be reported separately for each establishment on the “Establishment-Level Report(s).”
31 The “Headquarters Report” was formerly referred to as a “Type 3” headquarters report. Beginning with the 2022 EEO-1
Component 1 data collection, this report is now known simply as a “Headquarters Report.”
32 Please note that if an employer’s headquarters is a holding company, or similar type entity, with zero employees, it is still
necessary for the employer to file as a multi-establishment employer. The filing requirements for the EEO-1 Component 1 data
collection are based on employee counts across all establishments of the employer (i.e., a total of 100 or more employees and 50
or more employees for federal contractors meeting certain criteria). For example, if a holding company has non-headquarters
establishments which total 100 or more employees (or 50 or more employees for federal contractors meeting certain criteria), the
holding company must file as a multi-establishment employer and submit a “Headquarters Report” for the holding company and
“Establishment-Level Report” for each of its establishments.
33 The “Establishment-Level Report” replaces the former “Type 4” and “Type 8” non-headquarters establishment reports and the
former “Type 6” establishment list report. Beginning with the 2022 EEO-1 Component 1 data collection, a non-headquarters
establishment report is now known simply as an “Establishment-Level Report.”
34 Please note that if establishments are located at the same address (including, for example, suite number) and have both the same NAICS
code and the same EIN, the establishments must be combined into a single “Establishment-Level Report.” Such establishments are
considered one establishment for purposes of EEO-1 Component 1 reporting.

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Beginning with the 2022 EEO-1 Component 1 data collection, multi-establishment employers will
no longer be required to file a separate “type” of establishment report based on the size of an
individual non-headquarters establishment (i.e., establishments with 50 or more employees or
establishments with fewer than 50 employees). 35 Rather, in place of the “Type 4” and “Type 8”
reports and the former “Type 6” establishment list report, there will be a newly named
“Establishment-Level Report.” All multi-establishment employers will use an “EstablishmentLevel Report” to submit establishment-level employee demographic data for each of their nonheadquarters establishment(s) regardless of size.
With this change, a multi-establishment employer will no longer have to take the additional step
of counting employees in each establishment to determine whether to file a “Type 4” or “Type 8”
report. Multi-establishment employers will still be required to submit a “Headquarters Report” and
a “Consolidated Report.” However, all individual “Consolidated Reports” for multi-establishment
employers will be auto-populated and auto-generated with data from their “Headquarters Report”
and each “Establishment-Level Report” within the OFS. 36
Consolidated Report 37
A multi-establishment employer is required to submit and certify a “Consolidated Report.” The
“Consolidated Report” must include workforce demographic data for all the multi-establishment
employer’s employees (i.e., all employees at the employer’s headquarters and all its
establishments) categorized by job category and sex and race or ethnicity. In other words, the total
number of employees in the “Headquarters Report” plus the total number of employees in all the
multi-establishment employer’s “Establishment-Level Report(s)” must equal the total number of
employees in the “Consolidated Report.”
With the discontinuation of the “Type 6” establishment list report, 38 a “Consolidated Report” is
now auto-populated and auto-generated with data from a multi-establishment employer’s
“Headquarters Report” and “Establishment-Level Report(s)” within the EEOC’s electronic, webbased EEO-1 Component 1 Online Filing System (OFS) for all multi-establishment employers. 39
Although a “Consolidated Report” is now auto-populated and auto-generated in the OFS, a multiestablishment employer is still responsible for ensuring that the total employee count in the
35 Please note that if during the employer’s selected “workforce snapshot period,” an establishment had zero employees, the
employer should not file an “Establishment-Level Report” for that establishment. If the establishment appears in the employer’s
list of establishments from the previous reporting cycle, the filer should delete the establishment with zero employees from its list.
36
Please note that the 2022 EEO-1 Component 1 Data File Upload Specifications will allow users to indicate an “EstablishmentLevel Report” by using a Status Code (Field 2) of either 4 or 8 (i.e., filers can leverage either code to indicate an “EstablishmentLevel Report” when using the data file upload option to report workforce demographic data). Selecting either Status Code (4 or 8)
will have the identical effect of indicating that a report is an “Establishment-Level Report.”
37 The “Consolidated Report” was formerly referred to as a “Type 2” consolidated report. Beginning with the 2022 EEO-1
Component 1 data collection, this report is now known simply as a “Consolidated Report.”
38
The former “Type 6” establishment list report contained the name and address of each non-headquarters establishment with
fewer than 50 employees, as well as the total number of employees at each establishment. A multi-establishment employer choosing
the option to submit a “Type 6” establishment list report, instead of a “Type 8” report, was required to manually enter employee
demographic data by job category and sex and race or ethnicity into the accompanying “Type 2” consolidated report for every
employee of every establishment included on the “Type 6” establishment list report.
39 The “Consolidated Report” will be generated by the EEO-1 Component 1 Online Filing System (OFS) once the “Headquarters
Report” and all “Establishment-Level Report(s)” have been completed by the filer.

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“Consolidated Report” matches the total number of employees the filer is reporting in its
“Headquarters Report” and “Establishment-Level Report(s)” prior to certification. An employer
must also ensure that it has reported for all its establishments. For example, if an employer has 200
establishments, but only reported data for 150 establishments, the “Consolidated Report” will only
reflect the data for establishments submitted by the filer (i.e., 150). It is the responsibility of the
employer to ensure that data for each of its establishments has been submitted and that the
“Consolidated Report” matches that number. 40
8. WORKFORCE SNAPSHOT PERIOD
Workforce demographic data (i.e., employee data by job category and sex and race or ethnicity)
must include all full-time and part-time employees who were employed during an employerselected pay period (i.e., workforce snapshot period) in the fourth quarter (i.e., October 1 through
December 31) of the reporting year.
The workforce snapshot period for the [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 Report would
be an employer-selected pay period between October 1, [SPECIFIC REPORTING YEAR FOR
EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] and December 31, [SPECIFIC
REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]. 41
Employees must be counted by sex and race or ethnicity within the 10 specified job categories.
Each employee must be counted in only one of the job category, sex, race, and ethnicity
classifications (i.e., the employee must not be included more than once in a “Single-Establishment
Employer Report” or in a “Headquarters Report” and “Establishment-Level Report(s).”
If an employee was employed during the selected workforce snapshot period, then the employer
must include the employee in its reporting even if the employee resigned or was terminated during
or after the selected workforce snapshot period. If the employee was employed at any time during
the selected workforce snapshot period, then the employee must be reported. An employer is not
required to report employees who were not employed at any time during the selected workforce
snapshot period.
Beginning with 2023 EEO-1 Component 1 data collection, tentatively scheduled to open in 2024,
an employer that meets the employee threshold for EEO-1 Component 1 reporting purposes at any
time during the fourth quarter (i.e., October 1 through December 31) of the reporting year, may
not select a workforce snapshot period where it falls below the threshold in an effort to avoid the
As discussed in the below section of the Instruction Booklet entitled “REPORTING BY SEX,” the EEO-1 Component 1 data
collection currently provides only binary options (i.e., male or female) for reporting employee counts by sex, job category, and race
or ethnicity. However, employers may voluntarily choose to report employee demographic data for non-binary employees – that
is, employees who do not identify as exclusively male or female – by sex (i.e., non-binary), job category and race or ethnicity in
the “comments” section of the report(s). Employers that voluntarily choose to report non-binary employees in the “comments”
section of the report(s) should not assign such employees to the male or female categories or any other categories (i.e., job category
and race or ethnicity) within the report(s). For additional information on the voluntary reporting of non-binary employees, please
refer to the below section of the Instruction Booklet entitled “REPORTING BY SEX.”
41 An employer is not required to use the same workforce snapshot period (i.e., months, days) from the fourth quarter of the reporting
year that it selected in previous reporting cycles. For example, an employer that selected a workforce snapshot period with the
month/days of October 1 through October 14 for the 2021 EEO-1 Component 1 reporting cycle may select different month/days
(e.g., November 15 through November 30) for the 2022 EEO-1 Component 1 reporting cycle.
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filing requirement.
9. REPORTING BY RACE OR ETHNICITY
Voluntary self-identification by employees is the preferred method of identifying the race and/or
ethnicity information required for the EEO-1 Component 1 report.
The basic principles for race and ethnicity self-identification for purposes of the EEO-1
Component 1 report are:
(1) Offer employees the opportunity to self-identify.
(2) Provide a statement about the voluntary nature of this inquiry for employees.

For example, language such as the following may be used (employers may adapt this
language):
“The employer is subject to certain governmental recordkeeping and reporting
requirements for the administration of civil rights laws and regulations. In order to comply
with these laws, the employer invites employees to voluntarily self-identify their race or
ethnicity. Submission of this information is voluntary and refusal to provide it will not
subject you to any adverse treatment. The information obtained will be kept confidential
and may only be used in accordance with the provisions of applicable laws, executive
orders, and regulations, including those that require the information to be summarized and
reported to the federal government for civil rights enforcement. When reported, data will
not identify any specific individual.”
If an employee declines to self-identify their race and/or ethnicity, employment records or observer
identification may be used. Where records are maintained, they should be kept separately from the
employee’s basic personnel file or other records available to those responsible for personnel
decisions.
Definitions of the race and ethnicity categories used by the EEOC for purposes of EEO-1
Component 1 reporting are found below in Appendix B of the Instruction Booklet. Instructions for
assigning employees into these categories are also provided in Appendix B. 42
10. REPORTING BY SEX
The EEO-1 Component 1 data collection currently provides only binary options (i.e., male or
female) for reporting employee counts by sex, job category, and race or ethnicity. However,
employers may voluntarily choose to report employee demographic data for non-binary employees
– that is, employees who do not identify as exclusively male or female – by sex (i.e., non-binary),
job category and race or ethnicity in the “comments” section of the report(s). Employers that
voluntarily choose to report non-binary employees in the “comments” section of the report(s)
Please note that race and ethnicity designations, as used by the EEOC for the EEO-1 Component 1 report, do not denote scientific
definitions of anthropological origins. In addition, such designations do not control who is protected by Title VII’s prohibitions
against employment discrimination based on race or national origin.

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should not assign such employees to the male or female categories or any other categories (i.e.,
job category and race or ethnicity) within the report(s).
Single-establishment employers that voluntarily choose to report demographic data for non-binary
employees may do so in the “Certification Comments” section within the OFS. 43 Multiestablishment employers that voluntarily choose to report demographic data for non-binary
employees may do so in the “Headquarters or Establishment-Level Comments” section. 44 This
option will be available to multi-establishment filers through manual entry in the OFS as well as
through the data file upload function. 45
For employers that voluntarily choose to provide demographic data for their non-binary
employees, please follow the instructions in the above section of the Instruction Booklet entitled
“REPORTING BY RACE OR ETHNICITY” when deciding whether to report an employee as
male, female, or non-binary. If the sex reported by an employee during voluntary selfidentification differs from the sex recorded in the employee’s employment records, the employer
should report the former (i.e., self-identification) and not the latter (i.e., employment records).
Employers choosing to voluntarily report employee demographic data for non-binary employees
should preface any such data in the comments with the phrase “Additional Non-Binary Employee
Data:”. For example:
“Additional Non-Binary Employee Data: 1 non-binary employee in Job Category
Administrative Support Workers; Race/Ethnicity: White (Not Hispanic or Latino). 3 nonbinary employees in Job Category Professionals; Race/Ethnicity: Employee 1 – Black or
African American (Not Hispanic or Latino) / Employee 2 – Hispanic or Latino / Employee
3 – Two or More Races (Not Hispanic or Latino).” 46
For example, a single-establishment employer that has a total of 500 employees and is voluntarily reporting 2 of those employees
as non-binary in the “Certification Comments” section should show an employee count of 498 employees on the employer’s
“Single-Establishment Employer Report” (i.e., less the 2 non-binary employees reported in the comments section). Also, please
note that the voluntary reporting of non-binary employees does not impact the employee threshold for EEO-1 Component 1
reporting purposes. For example, if a non-federal contractor employer has a total of 100 employees, of which 2 are voluntarily
reported as non-binary in the comments, the employer is still required to file even though the total number of employees on the
employer’s “Single-Establishment Employer Report” would reflect only 98 employees.
44 For example, if a multi-establishment employer has a total of 1,000 employees and is voluntarily reporting 10 of those employees
as non-binary for the entire enterprise, the multi-establishment employer would do so in the comments section of the EEO-1
Component 1 report where those 10 non-binary employees are employed (i.e., on the appropriate “Headquarters Report” or
“Establishment-Level Report”). Using this same example, if there are 200 employees at the multi-establishment employer’s
headquarters and 5 of those employees are voluntarily reported as non-binary in the comments section, the “Headquarters Report”
would only show a total of 195 employees (i.e., less the 5 non-binary employees reported in the comments section). Continuing
this example, the remaining 5 non-binary employees would be reported in the comments section of the appropriate “EstablishmentLevel Report.” Finally, the employer’s “Consolidated Report” would show an employee count of 990 employees (i.e., less the 10
non-binary employees reported in the comments sections on the “Headquarters Report” and “Establishment-Level Report”). Also,
please note that the voluntary reporting of non-binary employees does not impact the employee threshold for EEO-1 Component 1
reporting purposes. For example, if a non-federal contractor employer has a total of 100 employees, of which 2 are voluntarily
reported as non-binary in the comments, the employer is still required to file even though the total number of employees on the
employer’s “Consolidated Report” would reflect only 98 employees.
45 The “Headquarters or Establishment-Level Comments” section allows a multi-establishment employer to provide comments for
its headquarters as well as each of its individual non-headquarters establishments at the establishment-level. Providing comments,
including demographic data for non-binary employees, is optional and not required.
46 Please note that filers voluntarily choosing to provide such data at the headquarters or establishment-level through the data file
upload option must ensure that any comments submitted do not contain any commas. See “Field 189” in the [SPECIFIC
REPORTING YEAR FOR DATA COLLECTION CYCLE WILL BE INSERTED BY EEOC] Data File Upload Specifications.
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11. CLASSIFICATION OF EMPLOYEES INTO JOB CATEGORIES
The 10 major job categories used by the EEOC for purposes of EEO-1 Component 1 reporting are
found below in Appendix C of the [SPECIFIC REPORTING YEAR FOR EACH COLLECTION
CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 Instruction Booklet. Each job
category includes a brief description of the skills and training required for occupations in that
category and examples of the job titles that fit each category. The examples provided are illustrative
and not intended to be exhaustive of all job titles in a job category. These job categories are
primarily based on the average skill level, knowledge, and responsibility involved in each
occupation within the job category. Employers should select the category which best reflects the
job function performed by each employee. 47
12. HOW TO REPORT NAICS CODES
The North American Industry Classification System (NAICS) code is used to identify the primary
industry in which a business or an establishment operates. The industry represents the primary
goods or services provided to the public and is very specific. For example, a business that provides
IT technical support to its clients would be classified as 541519 (Other Computer Related
Services), while a business that primarily provides software design or support services would be
classified as 541512 (Computer Systems Design Services).
Businesses that operate in more than one location may have different industries assigned to their
establishments. For example, a coffee company may have establishments for retail distribution of
their products, establishments for roasting and processing the coffee beans, as well as
establishments associated with warehousing supplies used by other aspects of the business’
operations. In this example, each of these establishments would have a different NAICS code.
Please note that if a business operates several industries at one establishment and thus, has several
NAICS codes associated with that one location, the employer must provide the one NAICS code
under which the largest number of employees work.
Each establishment must have an appropriate NAICS code associated with it. NAICS codes are
updated by the Office of Management and Budget (OMB) every five years (i.e., in years that end
in 2 or 7). For the [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL
BE INSERTED BY EEOC] EEO-1 Component 1 Report, the [MOST RECENT YEAR FOR
EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] NAICS codes should be used.
To identify the correct NAICS code for each establishment, an employer can search using
keywords for its business using the U.S. Census Bureau NAICS Search Tool at
https://www.census.gov/naics/.
13. HOW TO REPORT EMPLOYER IDENTIFICATION NUMBER (EIN)
The Employer Identification Number (EIN) is a unique, nine-digit identifier used to identify
business entities in the U.S. It is assigned by the IRS and is needed by all businesses that have
employees and certain others with no employees. For purposes of EEO-1 Component 1 reporting,
47 For additional assistance, employers should refer to the EEO-1 Component 1 Job Classification Guide, located within the OFS,
that maps Standard Occupational Classifications (SOC), occupational titles, and three-digit Census Job Codes to the EEO-1
Component 1 job categories.

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an EIN must be provided for a single-establishment employer and a multi-establishment employer’s
headquarters and each of its establishments.
However, if establishments are located at the same address (including, for example, suite number) and
have both the same NAICS code and the same EIN, the establishments must be combined into a single
“Establishment-Level Report.” Such establishments are considered one establishment for purposes of
EEO-1 Component 1 reporting.
Please note that if an establishment (e.g., subsidiary) has a different EIN than, for example, its “parent”
company, the establishment cannot file its EEO-1 Component 1 report separately from its “parent”
company. The “parent” company’s headquarters is responsible for filing “Establishment-Level
Report(s)” for all its establishments, even if the establishments have different EINs from the “parent”
company.48
14. HOW TO REPORT UNIQUE ENTITY ID FOR FEDERAL CONTRACTORS (only
applicable for employers that are federal contractors)
On April 4, 2022, the federal government stopped using the “Data Universal Numbering System”
(DUNS) to uniquely identify entities doing business with the federal government (i.e., federal
contractors). 49 The “Unique Entity ID” (UEI) created in SAM.gov is now the official identifier for
federal contractors. 50
For purposes of the EEO-1 Component 1 data collection, eligible federal contractors will no longer
provide the “DUNS Numbers” associated with their headquarters and/or establishment(s) in the
EEO-1 Component 1 Online Filing System (OFS) or in any data files uploaded to the OFS.
Beginning with the 2022 EEO-1 Component 1 data collection, employers (i.e., singleestablishment and multi-establishment employers) that are federal contractors must instead
provide UEIs. For example, a multi-establishment employer must provide UEIs for any
headquarters and/or establishment(s) which are federal contractors. 51
15. HOW TO REPORT REMOTE/TELEWORK EMPLOYEES
Employees who work remotely and/or telework must be included in an employer’s EEO-1
Component 1 report(s) by the specific establishment to which the employees report. Under no
circumstances, should an employee’s home address be reported on any EEO-1 Component
1 submission or report.
The temporary closure of a physical work site will normally not affect how employees are counted
Please note that a “parent” company, holding company, or other such corporate-type entity must file as a multi-establishment
employer (i.e., multi-establishment filer) for itself as well as any other commonly owned, controlled, managed, affiliated, or
associated establishments (e.g., subsidiaries, holdings).
49 Before April 4, 2022, the DUNS Number issued by Dun & Bradstreet was the official entity identifier used by the federal
government.
50 For more information on the federal government’s transition to the Unique Entity ID (i.e., UEI), see https://www.gsa.gov/aboutus/organization/federal-acquisition-service/technology-transformation-services/integrated-award-environment-iae/iae-systemsinformation-kit/unique-entity-identifier-update;
https://www.fsd.gov/gsafsd_sp?id=kb_article_view&sysparm_article=KB0041254&sys_kb_id=875189f21bee8d54937fa64ce54b
cbaa&spa=1 and https://sam.gov/content/duns-uei.
51 Please refer to the above section of the Instruction Booklet entitled “WHO MUST FILE” for federal contractor eligibility.
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on the EEO-1 Component 1 report. The fact that most, or even all, employees are teleworking will
typically not change EEO-1 Component 1 reporting if the employees continue to be assigned to,
or report to, a physical location or establishment. Those employees should be included on the
“Headquarters Report” or “Establishment-Level Report” for the physical location to which they
are assigned or report. If the employer has closed an establishment and reassigned an employee
from the closed establishment to another location, the reassigned employee should be included at
the establishment to which that employee reports or has been reassigned.
If a remote employee is not assigned to and does not report to any physical location on a permanent
basis, the employee should be counted at the establishment to which the employee’s manager
reports or is assigned. If an employee does not report to an establishment and the employee’s
manager also does not report to an establishment, the employee (and their manager) should be
included on the employer’s “Headquarters Report.”
If an employer operates entirely remotely and does not have any physical locations, not even a
headquarters office, the employer should report the address where the business is legally
registered, for example, a Post Office box in lieu of a physical address.
16. HOW TO REPORT EMPLOYEES AT CLIENT SITES
Workforce demographic data on employees working at client site locations must be included in an
employer’s EEO-1 Component 1 filing. For the 2022 EEO-1 Component 1 data collection,
employers continue to have the option to report employees working at client sites either by (1)
using the client site address as the location of the establishment or (2) reporting those employees
at an establishment of the employer (i.e., non-client site).
Beginning with the 2023 EEO-1 Component 1 data collection, tentatively scheduled to open in
2024, employers will be required to report employees working at client site locations at the address
of the client site. The address of the “client site” will serve as the location of the establishment for
any such employees. Employers will no longer have the option to report such employees at an
establishment of the employer (i.e., non-client site).
17. HOW TO REPORT EMPLOYEES AT U.S. GOVERNMENT AND MILITARY
LOCATIONS THAT ARE RESTRICTED FROM DISCLOSURE
A filer reporting employees located at a U.S. government or military site that is restricted from
disclosure may enter only the city, state, and zip code for that establishment(s). In the address field
for the establishment, the filer may enter either “SECRET LOCATION” or “CONFIDENTIAL
LOCATION.”
18. HOW TO REPORT AN ACQUISITION, SPINOFF, OR MERGER
If an employer has experienced an acquisition, spinoff, or merger since the last EEO-1 Component
1 reporting cycle, the employer must utilize the “Report Acquisition, Spinoff, or Merger” module
in the EEO-1 Component 1 Online Filing System (OFS) to report any changes to the EEOC. The
module will provide filers detailed guidance on how to accurately report such changes within the
OFS.
In addition, answers are provided below to a series of frequently asked questions (FAQs) regarding
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the filing responsibilities of employers that experienced an acquisition, spinoff, or merger since
the last EEO-1 Component 1 reporting cycle. 52
Filing Responsibilities of New Companies Created as the Result of a Merger
If a company/employer merged with another company/employer to create a new
company/employer, certain filing obligations apply depending on when the merger was completed.
Merger Completed before or during the Fourth Quarter (i.e., October 1 through December 31) of
the Reporting Year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC])
If the merger was completed before or during the fourth quarter (i.e., October 1 through December
31) of the reporting year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION
CYCLE WILL BE INSERTED BY EEOC]) and the new company otherwise meets the filing
eligibility requirements, the new company is responsible for submitting [SPECIFIC REPORTING
YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1
Component 1 data under a new “OFS Company ID” provided by the EEOC through the EEO-1
Component 1 Online Filing System (OFS).
Merger Completed after the Fourth Quarter (i.e., October 1 through December 31) of the Reporting
Year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE
INSERTED BY EEOC])
If the merger was completed after the fourth quarter (i.e., October 1 through December 31) of the
reporting year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL
BE INSERTED BY EEOC] and the new company otherwise meets the filing eligibility
requirements and has access to [SPECIFIC REPORTING YEAR FOR EACH COLLECTION
CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 data for a workforce snapshot
period from the fourth quarter of the reporting year for one or more of the companies that merged,
the new company is responsible for submitting [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 data under a
new “OFS Company ID” provided by the EEOC through the EEO-1 Component 1 Online Filing
System (OFS).
If the newly created company is eligible to file and does not have access to [SPECIFIC
REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]
EEO-1 Component 1 data for a workforce snapshot period from the fourth quarter of the reporting
year for one or more of the companies that merged, the newly created company should note this
in the “Certification Comments” within the OFS.
As a general matter, when a company completes an acquisition, spinoff, or merger and does not have access to all or part of the
required [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1
Component 1 data for an acquired, spun off, or former company, employers must note this in the “Certification Comments” within
the OFS. Employers should preface any such comments with the phrase “Additional ASM Information:”. Following this phrase,
an employer must provide a statement identifying the company (companies) and/or establishments for which the employer does
not have data as well as an explanation detailing why such data are not accessible for reporting purposes.

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Filing Responsibilities of Companies which Acquired Another Company
If a company/employer acquired another company/employer, certain filing obligations apply
depending on when the acquisition was completed.
Acquisition Completed before or during the Fourth Quarter (i.e., October 1 through December 31)
of the Reporting Year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION
CYCLE WILL BE INSERTED BY EEOC])
If the acquisition was completed before or during the fourth quarter (i.e., October 1 through
December 31) of the reporting year (i.e., [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC]) and the acquiring company otherwise
meets the filing eligibility requirements, the acquiring company is responsible for submitting
[SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED
BY EEOC] EEO-1 Component 1 data for itself and the newly acquired company.
Acquisition Completed after the Fourth Quarter (i.e., October 1 through December 31) of the
Reporting Year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC])
If the acquisition was completed after the fourth quarter (i.e., October 1 through December 31) of
the reporting year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC]) and the acquiring company otherwise meets the filing
eligibility requirements and has access to [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC]) EEO-1 Component 1 data for a
workforce snapshot period from the fourth quarter of the reporting year for the acquired company,
the acquiring company is responsible for submitting [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 data for itself
and the newly acquired company.
If the acquiring company is eligible to file and does not have access to [SPECIFIC REPORTING
YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1
Component 1 data for a workforce snapshot period from the fourth quarter of the reporting year
for the acquired company, the acquiring company should note this in the “Certification Comments”
within the OFS.
Filing Responsibilities of Companies which Completed a Spinoff
If a company/employer was spun off from another company/employer (e.g., a parent company),
certain filing obligations apply depending on when the spinoff was completed.
Spinoff Completed before or during the Fourth Quarter (i.e., October 1 through December 31) of
the Reporting Year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC])
If the spinoff was completed before or during the fourth quarter (i.e., October 1 through December
31) of the reporting year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION

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CYCLE WILL BE INSERTED BY EEOC]) and the spun off company otherwise meets the filing
eligibility requirements, the spun off company is responsible for submitting [SPECIFIC
REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]
EEO-1 Component 1 data for itself under its own “OFS Company ID.”
Spinoff Completed after the Fourth Quarter (i.e., October 1 through December 31) of the Reporting
Year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE
INSERTED BY EEOC]
If the spinoff was completed after the fourth quarter (i.e., October 1 through December 31) of the
reporting year (i.e., [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL
BE INSERTED BY EEOC]) and the spun off company otherwise meets the filing eligibility
requirements and has access to its [SPECIFIC REPORTING YEAR FOR EACH COLLECTION
CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 data for a workforce snapshot
period from the fourth quarter of the reporting year, the spun off company is responsible for
submitting [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE
INSERTED BY EEOC] EEO-1 Component 1 data for itself under its own “OFS Company ID.”
If the spun off company is eligible to file and does not have access to its [SPECIFIC REPORTING
YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1
Component 1 data for a workforce snapshot period from the fourth quarter of the reporting year,
the spun off company should note this in the “Certification Comments” within the OFS.
19. REPORTING PROCEDURES FOR THIRD-PARTY HUMAN
ORGANIZATIONS AND THEIR CLIENT EMPLOYERS 53

RESOURCE

Client Employers and Third-Party Human Resource Organizations
Clients of Professional Employer Organizations (PEOs), Administrative Services Organizations
(ASOs), Human Resource Outsourcing organizations (HROs), and similar third-party human
resource organizations are referred to as “client employers” by the EEOC for purposes of the EEO1 Component 1 data collection. A “client employer” is an employer that uses the services of a
third-party human resource organization (e.g., PEO, HRO, ASO). These services can include
preparing and filing the employer’s EEO-1 Component 1 report(s) on the employer’s behalf. The
employer using these services is referred to as a “client employer” of the third-party human
resource organization (e.g., PEO, HRO, ASO) that is filing on the employer’s behalf.
Client Employer Registration
Every eligible client employer on behalf of which a third-party human resource organization (e.g.,
PEO, HRO, ASO) chooses to file is required to have its own OFS employer registration under the
client employer’s EIN (i.e., Employer Identification Number). The employer registration contains
basic contact and location information and resides within the EEO-1 Component 1 Online Filing
System (OFS). This employer registration must be for the client employer itself and not the thirdparty human resource organization filing on the client employer’s behalf. Additionally, all filers
Third-party human resource organizations and their current or former client employers should refer to Appendix D of the
Instruction Booklet for additional information on their filing responsibilities.

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(e.g., client employers, PEOs, HROs, ASOs) are required to have an individual-level user account
to gain access to the EEO-1 Component 1 Online Filing System (OFS). 54
Filing on Behalf of a Client Employer
A third-party human resource organization (e.g., PEO, HRO, ASO) is not permitted to file for the
eligible client employer as an “establishment” of the third-party human resource organization. In
other words, a PEO, HRO, ASO or other third-party human resource organization (e.g., PEO,
HRO, ASO) may not submit an EEO-1 Component 1 report(s) that includes itself and a client
employer and/or a report that includes multiple client employers.
Additionally, third-party human resource organizations (e.g., PEOs, HROs, ASOs) are not
permitted to file only establishment report(s) for a client employer. Third-party human resource
organizations choosing to file on behalf of a single-establishment client employer (i.e., “SingleEstablishment Employer”) or a multi-establishment client employer (i.e., “Multi-Establishment
Employer”) must file all the reports that a client employer filing on its own behalf would be
required to file.
A third-party human resource organization (e.g., PEO, HRO, ASO) is also not permitted to file
EEO-1 Component 1 report(s) on behalf of a client employer for only a partial number of the client
employer’s employees. In such a situation, the client employer, not the third-party human resource
organization, must file EEO-1 Component 1 report(s) for all its employees.
Upload of Data File on Behalf of a Client Employer
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to submit data file
uploads on behalf of eligible client employers must do so separately for each client employer. The
bulk or consolidated upload of data files for multiple client employers by a third-party human
resource organization is not permitted. Every eligible client employer on behalf of which a thirdparty human resource organization is choosing to file must have a separate data file upload under
that client employer’s registration in the EEO-1 Component 1 Online Filing System (OFS).
Filing Responsibility of Client Employers
It is the responsibility of a client employer, if eligible, to ensure an EEO-1 Component 1 report is
filed on its behalf. If a third-party human resource organization (e.g., PEO, HRO, ASO) is choosing
to prepare and/or file the client employer’s EEO-1 Component 1 report, the client employer should
contact its third-party human resource organization to ensure it has the necessary information to
file. It is the responsibility of the client employer to ensure an EEO-1 Component 1 report is filed

54 A third-party human resource organization (e.g., PEO, HRO, ASO) may still prepare and file an EEO-1 Component 1 report on
behalf of eligible client employers. After the eligible client employer creates its company registration record, the client employer
can invite its third-party human resource organization (e.g., PEO, HRO, ASO) to create an associated user account. However, a
third-party human resource organization (e.g., PEO, HRO, ASO) is not permitted to certify a client employer’s EEO-1 Component
1 report. An official (i.e., employee) of the client employer (i.e., “certifying official”) must certify the client employer’s EEO-1
Component 1 report. The client employer’s “certifying official” cannot be from the third-party human resource organization (e.g.,
PEO, HRO, ASO).

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on its behalf. 55
If a third-party human resource organization (e.g., PEO, HRO, ASO) is choosing not to file an
eligible client employer’s [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC] EEO-1 Component 1 report, it is the responsibility of a client
employer to ensure a report is filed for its company.
Client Employer Certification
A third-party human resource organization (e.g., PEO, HRO, ASO) is not permitted to certify a
client employer’s EEO-1 Component 1 report. An official (i.e., employee) of the client employer
(i.e., “Certifying Official”) must certify the client employer’s EEO-1 Component 1 report. The
client employer’s “Certifying Official” cannot be from the third-party human resource
organization (e.g., PEO, HRO, ASO).
Third-Party Human Resource Organization Filing as an Employer
A third-party human resource organization (e.g., PEO, HRO, ASO) that is eligible to file an EEO1 Component 1 report in its own capacity as an employer must submit a report that includes only
the third-party human resource organization and its own establishments and employees. The thirdparty human resource organization’s own report must not include any of its client employers or
client employers’ establishments.
Requests by Client Employers for Prior Reports Filed by a Third-Party Human Resource
Organization
As in prior data collection years, the EEOC cannot provide client employers with any prior year
EEO-1 Component 1 report(s) filed on behalf of the client employer by a third-party human
resource organization (e.g., PEO, HRO, ASO). Client employers must contact the third-party
human resource organization (e.g., PEO, HRO, ASO) to obtain any such reports.
Processing of Client Employer Establishment Deletions/Registrations by the EEOC
In prior EEO-1 Component 1 data collection years, and upon request by a third-party human
resource organization (e.g., PEO, HRO, ASO), the EEOC and its EEO-1 Component 1 data
collection contractor manually processed client employer establishment deletions and employer
registrations, including bulk deletions and registrations. The EEOC and its contractor will no
longer process such deletions and registrations for an individual third-party human resource
organization (e.g., PEO, HRO, ASO) and/or its current or former client employers.
20. OFFICIAL CERTIFICATION OF SUBMISSION
Every eligible client employer on behalf of which a third-party human resource organization (e.g., PEO, HRO, ASO) chooses to
file is required to have its own OFS employer registration under the client employer’s EIN (i.e., Employer Identification Number).
The employer registration contains basic contact and location information and resides within the EEO-1 Component 1 Online Filing
System (OFS). This employer registration must be for the client employer itself and not the third-party human resource organization
filing on the client employer’s behalf. Additionally, all filers (e.g., client employers, PEOs, HROs, ASOs) are required to have an
individual-level user account to gain access to the EEO-1 Component 1 Online Filing System (OFS).
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Once an employer’s reports have been completed, the name and contact information for the
employer’s “Certifying Official” and the employer’s “Primary Point of Contact (POC) for EEO-1
Component 1 Reporting” (i.e., “Primary POC”) for receiving communications from the EEOC
regarding the report must be provided in the OFS. 56 The “Certifying Official” will certify to the
below statement within the OFS.
“I certify that the information, including any workforce demographic data, provided in this
report is correct and true to the best of my knowledge and was prepared in conformity with
the directions set forth in the form and accompanying instructions.”
Below this statement, the EEOC provides written notice to the “Certifying Official” that
“knowingly and [w]illfully false statements on this report are punishable by law, US Code, Title
18, Section 1001.”
Please note that if an employer fails to complete the final step to “Certify EEO-1 Component 1
Report(s)” within the EEO-1 Component 1 Online Filing System (OFS), the status of the
employer’s filing will be considered “incomplete” by the EEOC. 57 Any employer that has not
certified its submission in the OFS by the “published due date” (i.e., published deadline) will
receive a “Notice of Failure to File” from the EEOC requesting that employer certify its submission
in order to complete the required filing.
21. OFS INSTRUCTIONS FOR NEW AND RETURNING EMPLOYERS AND ACCOUNT
HOLDERS
Employers Filing for the First Time


All individuals responsible for filing the employer’s reports will be required to create an
individual user account associated with their email address to access the EEO-1 Component
1 Online Filing System (OFS). This can be done by visiting www.eeocdata.org/eeo1/signin
and
selecting
“Create
an
Account.”



After creating an account and signing in to the EEO-1 Component 1 Online Filing System
(OFS), account holders can register a new employer (i.e., company) by selecting “Add
Employer to List” on the home screen. 58



When adding a new employer, account holders will follow a series of prompts to determine
an employer’s eligibility to file. If eligibility is determined, account holders will be asked

56 Employers are permitted to have the same individual from the employer serve as both the “Certifying Official” and the “Primary
Point of Contact (POC) for EEO-1 Component 1 Reporting” (i.e., “Primary POC”) for the employer’s “Official Certification of
Submission.” However, the individual serving as the “Certifying Official” must be an official (i.e., employee) of the employer. For
example, employers using a third-party human resource organization (e.g., PEO, HRO, ASO) are not permitted to have an official
(i.e., employee) of the third-party human resource organization certify an employer’s EEO-1 Component 1 report(s). An official of
the employer must certify the employer’s EEO-1 Component 1 report(s).
57 Please note that even if the employer has submitted data for each of its required reports, the filing will not be considered complete
by the EEOC until the employer certifies its submission in the EEO-1 Component 1 Online Filing System (OFS).
58 After creating an account, users can communicate with the Filer Support Team via the EEO-1 Component 1 Message Center and
access supplementary helpful resources, if needed.

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to provide the: (1) Employer Identification Number (EIN); 59 (2) [MOST RECENT YEAR
WILL BE INSERTED BY EEOC] North American Industry Classification System
(NAICS) code; 60 (3) employer name (i.e., company name); and (4) employer headquarters
address.


During the new employer registration process, account holders will be provided with an
“OFS Company ID” and “Employer PIN.” The “OFS Company ID” and “Employer PIN”
can be shared with other OFS account holders to link their “Individual User Account” with
the employer profile.



After registering for an account, account holders may log in to the account using their
username (i.e., email address) and their password created in the account creation process.
If after linking an employer to a user account, the employer is not listed on the “Employer
List,” please contact the Filer Support Team via the Message Center.

Employers that have Previously Filed
Accessing an Employer’s Profile to Begin Submitting Reports
All individuals responsible for filing the employer’s reports will be required to create an
individual user account associated with their email address to sign in to the EEO-1
Component 1 Online Filing System (OFS) to access employer report(s) (formerly referred
to as company records) and/or submit EEO-1 Component 1 report(s).
Returning Users
Account holders may sign in to the EEO-1 Component 1 Online Filing System (OFS) by
visiting www.eeocdata.org/eeo1/signin and entering the email address and password
created beginning with the 2019/2020 EEO-1 Component 1 data collection cycle. Account
holders may be prompted to reset their password before proceeding. 61 Account holders
who do not know their password should select “Forgot Password.”
New Account Holders for Employers which have Previously Filed
New individuals responsible for filing reports for employers which have previously filed
will be required to create an individual user account associated with their email address to
access the EEO-1 Component 1 Online Filing System (OFS). This can be done by visiting
www.eeocdata.org/eeo1/signin and selecting “Create an Account.” After creating an
account and logging in to the OFS, new account holders can link their individual user
account to an employer by selecting “Add Employer to List” on the “My Employer List”
screen and entering the “OFS Company ID” and “Employer PIN” provided on the
employer’s annual filing notifications sent via U.S. postal mail and email prior to the
opening of the [SPECIFIC REPORTING YEAR WILL BE INSERTED BY EEOC] EEO1 Component 1 data collection.
If the employer’s EIN is associated with an existing EEO-1 Component 1 employer (i.e., company) report(s), the “New Employer
Registration” process cannot be completed. Please follow the instructions within the OFS to receive assistance from the Filer
Support Team.
60 To identify the correct [MOST RECENT YEAR WILL BE INSERTED BY EEOC] NAICS code for each establishment, an
employer can search using keywords for its business using the U.S. Census Bureau NAICS Search Tool at www.census.gov/naics/.
61 Please note that account holders are required to reset their password every 90 days.
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If an account holder does not have the “Employer ID” and “Employer PIN,” they should
obtain this information from their employer’s certifying official and enter it into the OFS.
If the account holder does not have access to the “Employer ID” and “Employer PIN,” they
should proceed in the OFS to answer a series of additional prompts. If the employer has
previously filed an EEO-1 Component 1 report, the account holder will be taken to a
“Change of Contact” form in the OFS. 62 Account holders will be asked to provide the
following in the “Change of Contact” form:






First Name, Last Name, Title, Phone Number, and Email Address of the person requesting
the change of contact
Employer Name and EIN
OFS Company ID (if known)
First Name, Last Name, Title, Phone Number, and Email Address of the new employer
(i.e., company) contact
A verification letter in PDF format on the employer’s letterhead (i.e., company’s
letterhead) from an authorized employer (i.e., company) representative approving this
change (e.g., CEO, President, General Counsel, CFO, Controller, Vice President of Human
Resources) is required.
Accessing Prior Year Filed Reports
EEO-1 Component 1 reports will be available in the EEO-1 Component 1 Online Filing
System (OFS) for all reports filed beginning with the 2015 EEO-1 Component 1 data
collection. 63 Select the employer in the “Employer List” to access the “Employer
Dashboard,” and click on “Historic EEO-1 Component 1 Reports” to download any
available prior year reports.

Adding/Changing an Employer’s Point of Contact (POC) 64
Account Holders Who Are Linked to an Employer in the OFS
Account holders whose accounts are linked to an employer in the EEO-1 Component 1
Online Filing System (OFS) can update the employer’s contact by selecting the appropriate
employer from the “Employer List” page. On the “Employer Dashboard” page, select the
“Confirm Employer Contacts” step. To add a new employer contact, select “Add New
Contact.” To update or delete an existing employer contact, select “Edit/Delete” next to the
appropriate contact.
Account Holders Who Are Not Linked to an Employer in the OFS
If an individual needs to update an employer’s point(s) of contact (POC(s)) and their user
account is not linked to an employer in the EEO-1 Component 1 Online Filing System
(OFS), the individual can visit www.eeocdata.or/eeo1 and log in to their user account or
Please note that a “Change of Contact” request must be reviewed by the Filer Support Team and may take up to 5–7 business
days to be approved.
63 Report availability is dependent on the employer’s filing history.
64 Please note that an employer may have more than one point of contact (POC) in the OFS. The EEOC strongly encourages
employers to include more than one person as a point of contact to ensure the employer receives critical notifications about the
EEO-1 Component 1 data collection.
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select “Get Started” to create a user account. Once logged in, account holders should select
“Add Employer to List” on the “Employer List” page. Account holders should follow the
prompts to link their individual user account to the employer. After successfully linking to
the employer, the account holder can select the employer on the “Employer List” page. On
the “Employer Dashboard” page, select the “Confirm Employer Contacts” step. To add a
new employer contact, select “Add New Contact” to update or delete an existing employer
contact, select “Edit/Delete” next to the appropriate contact.
Saving Entries within the OFS
As an account holder advances from one screen to another, the EEO-1 Component 1 Online
Filing System (OFS) saves their additions/deletions/changes as they click “Next,” “Save,”
“Confirm,” or “Submit.” An account holder must select “Next,” “Save,” “Confirm,” or
“Submit” and advance to the next page to save their additions/deletions/changes.
Otherwise, they will need to re-enter any additions/deletions/changes if they navigate away
from the OFS before clicking “Next,” “Save,” “Confirm,” or “Submit.”
Correcting Establishment Information in the OFS 65
Most employer information, including an EIN, can be edited in the EEO-1 Component 1
Online Filing System (OFS). “OFS Company ID” and “HQ/Establishment-Level Unit ID”
are the only exceptions – these cannot be edited by account holders. To update employer
information, log in to the OFS, and select an employer from “Your Employer List” page.
On the “Employer Dashboard” page, select the “Confirm Employer Details” step. Follow
the prompts within this step to confirm or update employer information. The [SPECIFIC
REPORTING YEAR WILL BE INSERTED BY EEOC] EEO-1 Component 1 User’s
Guide also has additional helpful technical information on how to edit employer
information, if wanted by a filer. The supplementary technical User’s Guide can be
accessed from the “Resource” page on the “Your Employer List” within the OFS or by
clicking the folder icon on the top of the screen.
Finishing Required Filing Steps in the OFS
As account holders complete each step of the process on the “Employer Dashboard,” each
step will change from “Go →” to “Complete.” After the “Report EEO-1 Component 1 Data
(Manual Entry or Data File Upload)” is shown as “Complete,” the “Review EEO-1
Component 1 Reports” and the “Certify EEO-1 Component 1 Reports” steps will show the
“Go →” button. Employers should review their report(s) to ensure data accuracy. When
the “Certify EEO-1 Component 1 Reports” displays “Go →,” select that step to complete
the certification process. Account holders will then proceed to a screen to enter “Certifying
Official” information and certify the EEO-1 Component 1 report(s). Account holders will
receive an email indicating that the EEO-1 Component 1 report(s) was certified.

65 Please note that once data collection closes for a particular reporting cycle, employers are not able to retroactively correct and/or
update any workforce demographic data reported during that cycle.

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Saving/Printing a Copy of Submitted/Certified EEO-1 Component 1 Reports
After certification, the “Employer Dashboard” will display “Thank you for completing the
EEO-1 Component 1 report for [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC].” Account holders may save
and/or print a PDF copy of their submitted and certified EEO-1 Component 1 report(s) by
selecting “Report” on this screen.
22. OFS REQUIRED FILING INFORMATION
As part of the EEO-1 Component 1 filing process, in addition to submitting workforce
demographic data if required to do so, an employer is required to provide within the EEO-1
Component 1 Online Filing System (OFS) certain identifying information on the employer and any
establishments being reported. The employer must also complete a set of questions to determine
whether it meets the threshold eligibility requirements to submit EEO-1 Component 1 workforce
demographic data. Additionally, all employers must indicate whether the employer and/or any
headquarters or establishments are federal contractors meeting certain criteria for purposes of
EEO-1 Component 1 reporting.
The information provided by an employer in the sections and sub-sections discussed below will
be included in the final certified downloadable employer’s report(s) generated by the OFS (i.e., a
“Single-Establishment Employer Report” for single-establishment employers and a “Consolidated
Report,” “Headquarters Report,” and “Establishment-Level Report(s)” for multi-establishment
employers). 66 Please note that all employers may preview and review uncertified PDF versions of
their reports prior to the employer’s official certification of the submission to the EEOC.
SECTION A – TYPE OF REPORT
This section denotes the specific “type” of report displayed (i.e., a “Single-Establishment
Employer Report,” a “Consolidated Report,” a “Headquarters Report,” or an “Establishment-Level
Report”).
Please note that the OFS will only generate one PDF report for a single-establishment employer
since such an employer is only required to submit a “Single-Establishment Employer Report.”
However, depending on the number of non-headquarters establishments for which a multiestablishment employer is reporting, there could be hundreds, or thousands, of reports generated
by the OFS for the employer. For example, a multi-establishment employer with a headquarters
and 500 non-headquarters establishments will have a total of 502 PDF reports generated by the
OFS (i.e., one “Consolidated Report” PDF report, one “Headquarters Report” PDF report, and 500
“Establishment-Level Report” PDF reports for its non-headquarters establishments). 67 These
66 Appendix E of the EEO-1 Component Instruction Booklet contains a “sample” of an EEO-1 Component 1 report(s) generated
by the EEOC’s EEO-1 Component 1 Online Filing System (OFS). Filers are not permitted to submit EEO-1 Component 1 workforce
demographic data using this sample. The EEOC requires electronic submission of EEO-1 Component 1 report(s) through the OFS,
the agency’s web-based data collection application (i.e., portal). The OFS is accessible at www.eeocdata.org/eeo1. The EEOC will
only accept EEO-1 Component 1 report(s) submitted and certified through the OFS. The EEOC will not accept reports submitted
via paper or through other non-OFS electronic means (e.g., email, CD-ROM). The EEOC will consider filers submitting reports
outside of the OFS to be non-compliant for purposes of their mandatory EEO-1 Component 1 filing obligation.
67 Please note that a multi-establishment employer can download all its reports into a single PDF document as in past reporting
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reports may be accessed within the OFS as individual PDFs or as a single PDF containing all
reports.
SECTION B – EMPLOYER IDENTIFICATION
This section contains identifying information about the single-establishment employer or multiestablishment employer, including the employer’s name, address, and “OFS Company ID.” For a
multi-establishment employer, the “employer name” would be, for example, the name of the parent
company or holding company. The “OFS Company ID” is a unique, seven-character identification
number associated with each employer. It is assigned by the EEOC.
SECTION C – HEADQUARTERS OR ESTABLISHMENT-LEVEL IDENTIFICATION
(if applicable)
This section applies only to a multi-establishment employer and contains identifying information
for the multi-establishment employer’s headquarters or a non-headquarters establishment. For a
single-establishment employer, this section will be denoted with a “N/A” (not applicable)
designation in the PDF version of its “Single-Establishment Employer Report.”
For a multi-establishment employer, this section may contain a “N/A” denoting that this section
was “not applicable” depending on the “type” of report associated with the PDF. For example, a
multi-establishment employer’s “Consolidated Report” will contain “N/A” designations in this
section since it is not a “Headquarters Report” or an “Establishment-Level Report.” However, this
employer’s “Headquarters Report” will contain the headquarters’ name, address, and Headquarters
ID in this section. For an “Establishment-Level Report,” this section will contain the name of the
specific establishment, along with the establishment’s address and Establishment-Level Unit ID.
SECTION D – EMPLOYER IDENTIFICATION NUMBER (EIN)
This section contains the Employer Identification Number (EIN). 68 For a single-establishment
employer, the employer’s EIN for its “Single-Establishment Employer Report” will be populated
in this section.
For a multi-establishment employer, the employer’s EIN for its headquarters will be populated in
this section of the employer’s “Headquarters Report.” 69 The EIN associated with a multiestablishment employer’s non-headquarters establishment(s) will be populated in this section on
each of its “Establishment-Level Report(s).” 70
SECTION E – EMPLOYER FILING ELIGIBILITY
As part of the EEO-1 Component 1 filing process, employers must answer a series of eligibility
questions within the OFS to determine if they are legally required to submit workforce
The Employer Identification Number (EIN) is a unique, nine-digit identifier used to identify business entities in the U.S. It is
assigned by the IRS and is needed by all businesses that have employees and certain others with no employees.
69 Additionally, for the employer’s “Consolidated Report” this section will be populated with the EIN provided for its headquarters.
70 For purposes of EEO-1 Component 1 reporting, an EIN must be provided for an employer’s headquarters and each of its establishments.
However, if establishments are located at the same address (including, for example, suite number) and have both the same NAICS code
and the same EIN, the establishments must be combined into a single “Establishment-Level Report.” Such establishments are considered
one establishment for purposes of EEO-1 Component 1 reporting.
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demographic data to the EEOC. 71 The employer’s response indicating whether it is eligible, not
eligible or no longer in business will be populated in this section of the employer’s EEO-1
Component 1 report(s). The three potential designations in this section include the following:
□ YES (Employer Is Eligible to File)
□ NO (Employer Is Not Eligible to File)
□ EMPLOYER NO LONGER IN BUSINESS
SECTION F – FEDERAL CONTRACTOR DESIGNATION (if applicable)
As part of the EEO-1 Component 1 filing process, single-establishment and multi-establishment
employers must identify whether they are a federal contractor (meeting certain criteria) 72 and if
so, provide their associated Unique Entity ID (UEI). 73 A multi-establishment employer must also
identify whether its headquarters or any non-headquarters establishment is a federal contractor and
if so, provide the UEI associated with each. Please note that OFCCP considers an employer (e.g.,
parent, headquarters) to be a federal contractor if any of the employer’s establishments are a federal
contractor. 74
This information is populated in “Section F – Federal Contractor Designation (if applicable)” on
the employer’s EEO-1 Component 1 report(s) generated by the OFS. These designations include
the following:
□ YES (Single-Establishment Employer is Federal Contractor) 75
□ YES (Multi-Establishment Employer is Federal Contractor) 76
□ YES (Headquarters is Federal Contractor) 77
71 The specific eligibility requirements for filing are discussed in detail in the above section of the Instruction Booklet entitled
“WHO MUST FILE.” Please note that an employer that receives an EEO-1 Component 1 filing notice from the EEOC but believes
it is not required to file must access the EEO-1 Component 1 Online Filing System (OFS) to complete the embedded eligibility
screener. If the screener confirms eligibility, the employer must follow the prompts to submit and certify the required workforce
demographic data. If the eligibility screener indicates the employer is ineligible to file, the employer must certify that it is ineligible
in the OFS. Failure to certify ineligibility through the OFS will result in future EEO-1 Component 1 filing notices being sent to the
employer by the EEOC. Additionally, an employer who receives an EEO-1 Component 1 filing notice from the EEOC but has
ceased operations and is no longer in business must also access the EEO-1 Component 1 Online Filing System (OFS) to complete
the eligibility screener. If the eligibility screener indicates the employer is ineligible to filer, the employer must certify that its
company is ineligible and no longer in business in the OFS. Similarly, failure to certify ineligibility through the OFS will result in
future EEO-1 Component 1 filing notices being sent to the employer by the EEOC.
72 Please refer to the above section of the Instruction Booklet entitled “WHO MUST FILE” for federal contractor eligibility.
73 On April 4, 2022, the federal government stopped using the “DUNS Number” to uniquely identify entities doing business with
the federal government (i.e., federal contractors). The “Unique Entity ID” (UEI) is now the official identifier for federal contractors.
See https://www.gsa.gov/about-us/organization/federal-acquisition-service/technology-transformation-services/integrated-awardenvironment-iae/iae-systems-information-kit/unique-entity-identifier-update and https://sam.gov/content/duns-uei. Beginning
with the 2022 EEO-1 Component 1 data collection, single-establishment and multi-establishment employers must provide their
“UEIs” instead of a “DUNS Number” for any headquarters and/or establishment(s) which are federal contractors.
74 For example, if an employer (i.e., parent company) has 1,000 non-headquarters establishments and of these establishments, only
one meets the eligibility requirements for a federal contractor, OFCCP considers the entire employer (i.e., parent, headquarters,
and all non-headquarters establishments) to be a federal contractor.
75 If a single-establishment employer indicates that it is a federal contractor, this box will be populated in “Section F” of the PDF
version of the employer’s “Single-Establishment Employer Report.”
76 If a multi-establishment employer indicates that it is a federal contractor, this box will be populated in “Section F” of the
employer’s “Consolidated Report.”
77 If a multi-establishment employer indicates that its headquarters is a federal contractor, this box will be populated in “Section F”
of the employer’s “Headquarters Report.”

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□ YES (Establishment is Federal Contractor) 78
□ YES (One or More Establishments is Federal Contractor) 79
SECTION G – NAICS INFORMATION
This section contains the NAICS (North American Industry Classification System) code used to
identify the primary industry in which the single-establishment or multi-establishment employer
operates, including any establishment(s). 80 Each employer and any establishment(s) must have an
appropriate NAICS code associated with it. NAICS codes are updated by the Office of
Management and Budget (OMB) every five years (i.e., in years that end in 2 or 7). For the
[SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED
BY EEOC] EEO-1 Component 1 Report, the [MOST RECENT YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC] NAICS codes should be used. 81 For
additional information on reporting a NAICS code by establishment, please refer to the above
section of the Instruction Booklet entitled “HOW TO REPORT NAICS CODES.”
SECTION H – WORKFORCE DEMOGRAPHIC DATA
This section contains workforce demographic data by job category and sex and race or ethnicity
submitted by eligible single-establishment and multi-establishment employers. The total reported
employees within each job category should equal the sum of each employee reported for that job
category across all sex and race/ethnicity categories. Additionally, the total number of employees
within each sex and race/ethnicity category should equal the sum of that particular category across
all job categories. 82 This section will also provide the “current reporting year totals” and “previous
reporting year totals” for each sex and race/ethnicity category across all job categories.
SECTION I – WORKFORCE SNAPSHOT PERIOD
This section contains the dates (i.e., month, day, year) of the “workforce snapshot period” 83
78 If a multi-establishment employer indicates that a specific establishment is a federal contractor, this box will be populated in
“Section F” of the “Establishment-Level Report” for that establishment.
79
If a multi-establishment employer indicates that any non-headquarters establishment is a federal contractor, this box will be
populated in “Section F” of each of the employer’s “Consolidated Report.”
80
Please note that if an employer operates several industries at one establishment and thus has several NAICS codes associated
with that one location, the employer must provide the one NAICS code under which the largest number of employees work.
Additionally, for the “Headquarters Report,” the multi-establishment employer must provide the one NAICS code under which the
largest number of employees work for the multi-establishment employer as a whole (i.e., across all establishments).
81 To identify the correct NAICS code for each establishment, an employer can search using keywords for its business using the
U.S. Census Bureau NAICS Search Tool at www.census.gov/naics.
82 As discussed in the above section of the Instruction Booklet entitled “REPORTING BY SEX,” the EEO-1 Component 1 data
collection currently provides only binary options (i.e., male or female) for reporting employee counts by sex, job category, and race
or ethnicity. However, employers may voluntarily choose to report employee demographic data for non-binary employees – that
is, employees who do not identify as exclusively male or female – by sex (i.e., non-binary), job category and race or ethnicity in
the “comments” section of the report(s). Employers that voluntarily choose to report non-binary employees in the “comments”
section of the report(s) should not assign such employees to the male or female categories or any other categories (i.e., job category
and race or ethnicity) within the report(s). For additional information on the voluntary reporting of non-binary employees, please
refer to the above section of the Instruction Booklet entitled “REPORTING BY SEX.”
83 The “workforce snapshot period” must include all full-time and part-time employees who were employed during an employerselected pay period in the fourth quarter (i.e., October 1 through December 31) of the reporting year (i.e., the “workforce snapshot
period”). The workforce snapshot period for the [SPECIFIC REPORTING YEAR WILL BE INSERTED BY EEOC] EEO-1
Component 1 report would be an employer-selected pay period between October 1, [SPECIFIC REPORTING YEAR FOR EACH

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selected by an eligible single-establishment or multi-establishment employer for the reporting of
its workforce demographic data (i.e., employee data by job category and sex and race or ethnicity).
These dates must be entered into the OFS and will populate under the table containing each report’s
workforce demographic data. For additional information on reporting an employer’s workforce
snapshot period, please refer to the above section of the Instruction Booklet entitled
“WORKFORCE SNAPSHOT PERIOD.”
SECTION J – HEADQUARTERS OR ESTABLISHMENT-LEVEL COMMENTS
(optional)
Employers may provide the EEOC with any additional comments regarding its headquarters or
any of its non-headquarters establishments. Any comments provided for the employer’s
headquarters or any non-headquarters establishment will be populated under this section in the
applicable report(s) generated by the OFS. If no comments are submitted, the statement “No
Comments Provided” will be populated in this section of the PDF(s). Please note this section is
not applicable to a multi-establishment employer’s “Consolidated Report,” which will be
populated with the statement “Not Applicable.” Employers may also leave additional comments
in “Section K” under the “Certification Comments” sub-section. Any comments provided will be
populated in “Section K” of a multi-establishment employer’s “Consolidated Report” and in
“Section K” of a single-establishment employer’s “Single-Establishment Employer Report.”
Voluntary Reporting of Employee Demographic Data for Non-Binary Gender Employees: As
discussed in the above section of the Instruction Booklet entitled “REPORTING BY SEX,” the
EEO-1 Component 1 data collection currently provides only binary options (i.e., male or female)
for reporting employee counts by sex, job category, and race or ethnicity. However, employers
may voluntarily choose to report employee demographic data for non-binary employees – that is,
employees who do not identify as exclusively male or female – by sex (i.e., non-binary), job
category and race or ethnicity in the “comments” section of the report(s). Employers that
voluntarily choose to report non-binary employees in the “comments” section of the report(s)
should not assign such employees to the male or female categories or any other categories (i.e.,
job category and race or ethnicity) within the report(s).
Single-establishment employers that voluntarily choose to report demographic data for non-binary
employees may do so in the “Certification Comments” section within the OFS. 84 Multiestablishment employers that voluntarily choose to report demographic data for non-binary
employees may do so in the “Headquarters or Establishment-Level Comments” section. 85 This
COLLECTION CYCLE WILL BE INSERTED BY EEOC] and December 31, [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC].
84 For example, a single-establishment employer that has a total of 500 employees and is voluntarily reporting 2 of those employees
as non-binary in the “Certification Comments” section should show an employee count of 498 employees on the employer’s
“Single-Establishment Employer Report” (i.e., less the 2 non-binary employees reported in the comments section). Also, please
note that the voluntary reporting of non-binary employees does not impact the employee threshold for EEO-1 Component 1
reporting purposes. For example, if a non-federal contractor employer has a total of 100 employees, of which 2 are voluntarily
reported as non-binary in the comments, the employer is still required to file even though the total number of employees on the
employer’s “Single-Establishment Employer Report” would reflect only 98 employees.
85 For example, if a multi-establishment employer has a total of 1,000 employees and is voluntarily reporting 10 of those employees
as non-binary for the entire enterprise, the multi-establishment employer would do so in the comments section of the EEO-1
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option will be available to multi-establishment employers through manual entry in the OFS as well
as through the data file upload function. 86
For employers that voluntarily choose to provide demographic data for their non-binary
employees, please follow the instructions in the above section of the Instruction Booklet entitled
“REPORTING BY RACE OR ETHNICITY” when deciding whether to report an employee as
male, female, or non-binary. If the sex reported by an employee during voluntary selfidentification differs from the sex recorded in the employee’s employment records, the employer
should report the former (i.e., self-identification) and not the latter (i.e., employment records).
Employers choosing to voluntarily report employee demographic data for non-binary employees
should preface any such data in the comments with the phrase “Additional Non-Binary Employee
Data:”. For example:
“Additional Non-Binary Employee Data: 1 non-binary employee in Job Category
Administrative Support Workers; Race/Ethnicity: White (Not Hispanic or Latino). 3 nonbinary employees in Job Category Professionals; Race/Ethnicity: Employee 1 – Black or
African American (Not Hispanic or Latino) / Employee 2 – Hispanic or Latino / Employee
3 – Two or More Races (Not Hispanic or Latino).” 87
SECTION K – OFFICIAL CERTIFICATION OF SUBMISSION
For a single-establishment employer, this section will appear in the PDF version of the employer’s
“Single-Establishment Employer Report” generated by the OFS. For a multi-establishment
employer, this section will appear in the PDF version of the employer’s “Consolidated Report.”
Please note that if an employer fails to complete the final step to “Certify EEO-1 Component 1
Report(s)” within the EEO-1 Component 1 Online Filing System (OFS), the status of the
employer’s filing will be considered “incomplete” by the EEOC. Even if the employer has
submitted data for each of its required reports, the filing will not be considered complete by the
EEOC until the employer certifies its submission in the EEO-1 Component 1 Online Filing System
(OFS). Any employer that has not certified its submission in the OFS by the “published due date”
(i.e., published deadline) will receive a “Notice of Failure to File” from the EEOC requesting that
the employer certify its submission in order to complete the required filing.
“Establishment-Level Report”). Using this same example, if there are 200 employees at the multi-establishment employer’s
headquarters and 5 of those employees are voluntarily reported as non-binary in the comments section, the “Headquarters Report”
would only show a total of 195 employees (i.e., less the 5 non-binary employees reported in the comments section). Continuing
this example, the remaining 5 non-binary employees would be reported in the comments section of the appropriate “EstablishmentLevel Report.” Finally, the employer’s “Consolidated Report” would show an employee count of 990 employees (i.e., less the 10
non-binary employees reported in the comments sections on the “Headquarters Report” and “Establishment-Level Report”). Also,
please note that the voluntary reporting of non-binary employees does not impact the employee threshold for EEO-1 Component 1
reporting purposes. For example, if a non-federal contractor employer has a total of 100 employees, of which 2 are voluntarily
reported as non-binary in the comments, the employer is still required to file even though the total number of employees on the
employer’s “Consolidated Report” would reflect only 98 employees.
86 The “Headquarters or Establishment-Level Comments” section allows a multi-establishment employer to provide comments for
its headquarters as well as each of its individual non-headquarters establishments at the establishment-level. Providing comments,
including demographic data for non-binary employees, is optional and not required.
87 Please note that filers voluntarily choosing to provide such data at the headquarters or establishment-level through the data file
upload option must ensure that any comments submitted do not contain any commas. See “Field 189” in the [SPECIFIC
REPORTING YEAR FOR DATA COLLECTION CYCLE WILL BE INSERTED BY EEOC] Data File Upload Specifications.

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This section contains the following information:
Employer Identification
This section contains identifying information about the single-establishment employer or
multi-establishment employer, including the employer’s name, address, and “OFS
Company ID.” For a multi-establishment employer, the “Employer Name” would be, for
example, the name of the parent company or holding company, and the “Address” would
be the associated address. The “OFS Company ID” is a unique, seven-character
identification number associated with each employer. It is assigned by the EEOC.
Certification Comments
A single-establishment or multi-establishment employer may provide the EEOC with any
final comments regarding its submission in this sub-section. 88 Any comments provided
will be populated in this section. If no comments are submitted, a “No Certification
Comments Provided” will be populated in this section.
Certification Statement
The employer’s “Certifying Official” will certify to the following statement in the OFS:
“I certify that the information, including any workforce demographic data, provided in this
report is correct and true to the best of my knowledge and was prepared in conformity with
the directions set forth in the form and accompanying instructions.”
Below this statement, the EEOC provides written notice to the “Certifying Official” that
“knowingly and [w]illfully false statements on this report are punishable by law, US Code,
Title 18, Section 1001.”
Date of Certification
The OFS will automatically generate the month, day, year, and time (e.g., May 2, 2023
9:00 AM) that the submission was certified by the employer in the OFS.
Employer’s Certifying Official
The individual serving as the “Certifying Official” must be an official (i.e., employee) of
As discussed in the above section of the Instruction Booklet entitled “REPORTING BY SEX,” the EEO-1 Component 1 data
collection currently provides only binary options (i.e., male or female) for reporting employee counts by sex, job category, and race
or ethnicity. However, employers may voluntarily choose to report employee demographic data for non-binary employees – that
is, employees who do not identify as exclusively male or female – by sex (i.e., non-binary), job category and race or ethnicity in
the “comments” section of the report(s). Employers that voluntarily choose to report non-binary employees in the “comments”
section of the report(s) should not assign such employees to the male or female categories or any other categories (i.e., job category
and race or ethnicity) within the report(s). Single-establishment employers that voluntarily choose to report demographic data for
non-binary employees may do so in the “Certification Comments” section within the OFS. Multi-establishment employers that
voluntarily choose to report demographic data for non-binary employees may do so in the “Headquarters or Establishment-Level
Comments” section.

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the employer. For example, an employer using a third-party human resource organization
(e.g., PEO, HRO, ASO) is not permitted to have an official (i.e., employee) of the thirdparty human resource organization certify an employer’s EEO-1 Component 1 report(s).
An official of the employer must certify the employer’s EEO-1 Component 1 report(s).
This sub-section contains the following information:
▪
▪
▪
▪

Name of Employer’s Certifying Official
Title of Certifying Official
Email Address of Certifying Official
Telephone Number of Certifying Official

Primary Point of Contact (POC) for EEO-1 Component 1 Reporting
In addition to a “Certifying Official,” employers must also provide a “Primary Point of
Contact (POC) for EEO-1 Component 1 Reporting” (i.e., “Primary POC”) for receiving
communications from the EEOC regarding the report. Employers may choose the same
individual to serve as both the employer’s “Certifying Official” and the “Primary Point of
Contact (POC) for EEO-1 Component 1 Reporting” (i.e., “Primary POC”). Alternatively,
an employer may provide a different individual to be its “Primary Point of Contact (POC)
for EEO-1 Component 1 Reporting” (i.e., “Primary POC”). However, the “Certifying
Official” must be an employee of the employer and not, for example, an employee or
representative of the employer’s third-party human resource organization (e.g., PEO, ASO,
HRO) filing on the employer’s behalf.
This sub-section contains the following information:





Name of Primary POC
Title and Employer of Primary POC
Email Address of Primary POC
Telephone Number of Primary POC

23. FAILURE TO FILE
The deadline to file the [SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE
WILL BE INSERTED BY EEOC] EEO-1 Component 1 report is [SPECIFIC DATE FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC] (i.e., “Published Due Date”).
Following the [SPECIFIC DATE FOR EACH COLLECTION CYCLE WILL BE INSERTED BY
EEOC] “Published Due Date” deadline, the EEOC will enter the “Failure to File” phase. All
employers who have not submitted and certified their mandatory [SPECIFIC REPORTING YEAR
FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1
Report(s) by the [SPECIFIC DATE FOR EACH COLLECTION CYCLE WILL BE INSERTED
BY EEOC] “Published Due Date” deadline will receive a “Notice of Failure to File” from the
EEOC instructing them to submit and certify their data as soon as possible, and no later than
[SPECIFIC DATE FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] (i.e.,
“Failure to File” deadline).
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After the [SPECIFIC DATE FOR EACH COLLECTION CYCLE WILL BE INSERTED BY
EEOC] “Failure to File” deadline passes, no additional [SPECIFIC REPORTING YEAR FOR
EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 report(s)
will be accepted, and eligible employers will be out of compliance with their mandatory
[SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED
BY EEOC] EEO-1 Component 1 filing obligations. Pursuant to EEOC regulation 29 CFR 1602.9,
any employer “failing or refusing” to file when required to do so, may be compelled to file by
order of a U.S. District Court, upon application by the Commission. 89
24. APPLICATION FOR UNDUE HARDSHIP EXEMPTION 90
Pursuant to 29 CFR § 1602.10, if an employer claims that the preparation or filing of the
[SPECIFIC REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED
BY EEOC] EEO-1 Component 1 report would create undue hardship, the employer may apply to
the Commission for an exemption from the requirements set forth in this Instruction Booklet by
submitting a written exemption application pursuant to the directions contained herein.
The employer must demonstrate how the preparation or filing of the [SPECIFIC REPORTING
YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1
Component 1 report would create undue hardship in the written exemption application. 91 Please
note that while an application is pending, the applicant (i.e., employer) must continue to collect
and prepare the data required for the report in case the exemption request is denied.
All exemption applications must be submitted in writing and sent to the following mailing address:
U.S. Equal Employment Opportunity Commission (EEOC)
Attention: Office of Enterprise Data and Analytics (OEDA)
131 M Street NE
Washington, DC 20507
Exemption applications must be postmarked on or before the following date: [SPECIFIC DATE
FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]. Only exemption applications
submitted according to the above instructions will be accepted for consideration. 92 Filers are not
permitted to submit an exemption application via email or through the EEO-1 Component 1 Online
Filing System (OFS). Additionally, any exemption applications postmarked after the above date
will not be considered.

See https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XIV/part-1602/subpart-B/section-1602.9.
29 CFR § 1602.10 refers employers to “[I]nstruction 5” of the Instruction Booklet for directions on how to submit an exemption
application according to this “instruction” and references “section 5” of the instructions. For purposes of the [SPECIFIC
REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 data
collection, these directions are provided in this section of the Instruction Booklet.
91 Please note that an application for an undue hardship exemption is for consideration of an exemption from filing an employer’s
mandatory EEO-1 Component 1 report. It is not an application for an extension of either the “Published Due Date” deadline or the
final “Failure to File” deadline.
92 Please note that applications submitted to EEOC field offices or other offices within EEOC headquarters will not be considered.
89
90

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25. CONFIDENTIALITY
All reports and any information from individual reports are subject to the confidentiality provisions
of Section 709(e) of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-8(e), as amended
(Title VII) and may not be made public by the EEOC prior to the institution of any proceeding
under Title VII involving the EEO-1 Component 1 data. Any EEOC employee who violates this
prohibition may be found guilty of a criminal misdemeanor and could be fined or imprisoned. The
confidentiality requirements allow the EEOC to publish only aggregated data, and only in a manner
that does not identify any particular filer or reveal any individual employee’s personal information.
The Office of Federal Contract Compliance Programs (OFCCP) obtains EEO-1 Component 1
reports for federal contractors pursuant to its own legal authority under Executive Order 11246
and its implementing regulations. Because OFCCP obtains EEO-1 data for contractors under its
own E.O. 11246 authority, some courts have ruled that the Title VII prohibition against disclosure
does not apply to OFCCP’s collection of EEO-1 data. See, e.g., United Techs. Corp. v. Marshall,
464 F. Supp. 845, 851-52 (D. Conn. 1979); Sears Roebuck & Co. v. Gen. Servs. Admin., 509 F.2d
527, 529 (D.C. Cir. 1974). Accordingly, the EEO-1 Component 1 data of federal contractors
received by OFCCP may be subject to potential disclosure by OFCCP under the Freedom of
Information Act (FOIA), although FOIA exemptions may prevent disclosure. For more
information, see the Department of Labor’s FOIA regulations at 41 CFR part 70 and frequently
asked questions (Freedom of Information Act (FOIA) Frequently Asked Questions | U.S.
Department of Labor (dol.gov)) at https://www.dol.gov/agencies/ofccp/faqs/foia.
With respect to other federal agencies with a legitimate law enforcement purpose but without
OFCCP’S independent authority to collect EEO-1 data, the EEOC gives access to information
collected under Title VII only if the agencies agree, by letter or memorandum of understanding, to
comply with the confidentiality provisions of Title VII. In addition, section 709(d) 42 U.S.C.
2000e-8(d) provides that the EEOC shall furnish upon request and without cost to state or local
civil rights agencies information about employers in their jurisdiction on the condition that they
not make it public prior to starting a proceeding under state or local law involving such
information. The EEOC shares EEO-1 data with state or local Fair Employment Practices
Agencies (FEPAs) pursuant to Worksharing Agreements that impose obligations on the contracted
FEPA with respect to confidentiality, privacy, and data security. On a case-by-case basis, the
EEOC may share EEO-1 data with a FEPA that does not have a Worksharing Agreement, but only
if that FEPA agrees to comply with confidentiality, privacy, and data security obligations similar
to those imposed on FEPAs with Worksharing Agreements.
26. BURDEN ESTIMATE
Comments regarding the burden associated with the collection of EEO-1 Component 1 data under the
Paperwork Reduction Act (PRA),93 including suggestions for reducing burden, may be submitted at
any time to either the EEOC or the Office of Management and Budget (OMB) at the following
mailing addresses:
U.S. Equal Employment Opportunity Commission (EEOC)
Attention: Office of Enterprise Data and Analytics (OEDA)
93

The full text of the OMB regulations on the PRA may be found at 5 CFR Part 1320.

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131 M Street NE
Washington, DC 20507
OR
Paperwork Reduction Act (3046-0049)
Office of Management and Budget
Washington, DC 20503

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APPENDIX A
DEFINITIONS
“Account Holder” refers to an individual who has access to the EEO-1 Component 1 Online
Filing System (OFS) via a user account associated with their email address.
“Certifying Official” refers to the official (i.e., employee) designated by an employer to certify
the employer’s EEO-1 Component 1 report submission to the EEOC. The “certifying official” will
certify to the following statement within the OFS: “I certify that the information, including any
workforce demographic data, provided in this report is correct and true to the best of my
knowledge and was prepared in conformity with the directions set forth in the form and
accompanying instructions.” Prior to certifying to this statement, the EEOC provides written
notice to the “Certifying Official” that “knowingly and [w]illfully false statements on this report
are punishable by law, US Code, Title 18, Section 1001.”
The individual serving as the “Certifying Official” must be an official (i.e., employee) of the
employer. For example, an employer using a third-party human resource organization (e.g., PEO,
HRO, ASO) is not permitted to have an official (i.e., employee) of the third-party human resource
organization certify an employer’s EEO-1 Component 1 report(s). An official of the employer
must certify the employer’s EEO-1 Component 1 report(s).
“Commission” refers to the U.S. Equal Employment Opportunity Commission (EEOC).
“EEO-1 Component 1 Online Filing System (OFS)” refers to the web-based application (i.e.,
portal) used to electronically collect EEO-1 Component 1 data by the EEOC.
“EIN (Employer Identification Number)” is a unique, nine-digit identifier used to identify
business entities in the U.S. It is assigned by the IRS and is needed by all businesses that have
employees and certain others with no employees.
“Employee” means any individual on the payroll of an employer who is an employee for purposes
of the employers withholding of Social Security taxes except insurance sales agents who are
considered to be employees for such purposes solely because of the provisions of 26 USC 3121
(d)(3)(B) (the Internal Revenue Code). Leased employees are included in this definition.
“Employer” under Section 701(b), Title VII of the Civil Rights Act of 1964, as amended, means
a person engaged in an industry affecting commerce who has 15 or more employees for each
working day in each of 20 or more calendar weeks in the current or preceding calendar year, and
any agent of such a person, but such term does not include the United States, a corporation wholly
owned by the government of the United States, American Indian or Alaska Native tribes, or any
department or agency of the District of Columbia subject by statute to procedures of the
competitive service (as defined in section 2102 of Title 5 of the United States Code), or a bona
fide private membership club (other than a labor organization) which is exempt from taxation
under Section 501(c) of the Internal Revenue Code of 1954.
“Employer Dashboard” refers to a page in the EEO-1 Component 1 Online Filing System (OFS)
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that displays a particular employer’s details, shows the various actions and milestones required to
complete the EEO-1 Component 1, and makes reports from previous reporting years available.
“Establishment” is generally a single physical location where business is conducted or where
services or industrial operations are performed (e.g., factory, mill, store, hotel, movie theater, mine,
farm, airline terminal, sales office, warehouse, or central administrative office). 94 Establishments
at different physical locations must be reported as separate establishments even if conducting the
same business or performing the same services or industrial operations.
“Establishment-Level Unit ID” refers to a unique, alphanumeric, seven-character identifier that
corresponds to a specific establishment.
“Leased Employee”, for EEO-1 Component 1 reporting only, means a permanent employee
provided by an employment agency for a fee to an outside company for which the employment
agency handles all personnel tasks including payroll, staffing, benefit payments and compliance
reporting. The employment agency shall include leased employees in its EEO-1 report. For EEO1 Component 1 reporting purposes only, the term “employee” shall not include persons who are
hired on a casual basis for a specified time, or for the duration of a specified job (for example, a
person at a construction site whose employment relationship is expected to terminate with the end
of the employee’s work at the site); persons temporarily employed in any industry other than
construction, such as temporary office workers, mariners, stevedores, lumber yard workers, etc.,
who are hired through a hiring hall or other referral arrangement, through an employee contractor
or agent, or by some individual hiring arrangement, or persons (EXCEPT leased employees) on
the payroll of an employment agency who are referred by such agency for work to be performed
on the premises of another employer under that employer’s direction and control. These definitions
are only for purposes of clarifying who reports these individuals on the EEO-1 Component 1 and
do not have legal ramifications as to the analysis of whether a particular individual is an employee
or an independent contractor. That is done under the factors enumerated by the Supreme Court in
Nationwide Mutual Ins. Co. v. Darden, 503 U.S. 318 (1992).
“Headquarters Unit ID” refers to a unique, alphanumeric, seven-character identifier that
corresponds to a company’s headquarters in the EEO-1 Component 1 Online Filing System (OFS).
“NAICS” refers to the North American Industry Classification System (NAICS). This code is
used to identify the primary industry in which a business or an establishment operates and
represents the specific primary goods or services provided to the public. 95
“New Account Holders” refers to account holders created as part of the current reporting year’s
collection.
“OEDA” (Office of Enterprise Data and Analytics) refers to the office within the EEOC which

administers the agency’s EEO data collections, including the EEO-1 Component 1. Since its

See Frequently Asked Question 2 (What is an establishment?) at www.census.gov/naics for the U.S. Census Bureau’s North
American Industry Classification System (NAICS) definition.
95 See www.census.gov/naics.
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creation in May 2018, OEDA has worked to modernize the agency’s EEO data collections and
improve the quality of data collected. OEDA has also streamlined functions, such as providing
additional self-service options, resource materials, and an online support message center.
“OFCCP” refers to the Office of Federal Contract Compliance Programs, U.S. Department of
Labor, which administers and enforces Executive Order 11246, as amended.
“OFS” is an abbreviated reference to the “EEO-1 Component 1 Online Filing System (OFS).”
“OFS Company ID” refers to a unique, alphanumeric, seven-character identifier that corresponds
to a company in the EEO-1 Component 1 Online Filing System (OFS).
“Point of Contact” refers to an individual designated by the employer to receive communications
from the EEOC. The EEOC strongly encourages employers to include more than one individual
as a point of contact to ensure the employer receives critical notifications.
“Primary Point of Contact for EEO-1 Component 1 Reporting” refers to the individual
designated within “Section K – Official Certification of Submission” as the “Primary Point of
Contact (POC) for EEO-1 Component 1 Reporting” (i.e., “Primary POC”) for receiving
communications from the EEOC regarding the report. In addition to a “Certifying Official,”
employers must also provide a “Primary Point of Contact (POC) for EEO-1 Component 1
Reporting” (i.e., “Primary POC”). Employers may choose the same individual to serve as both the
employer’s “Certifying Official” and the “Primary Point of Contact (POC) for EEO-1 Component
1 Reporting” (i.e., “Primary POC”). Alternatively, an employer may provide a different individual
to be its “Primary Point of Contact (POC) for EEO-1 Component 1 Reporting” (i.e., “Primary
POC”). However, the “Certifying Official” must be an employee of the employer and not, for
example, an employee or representative of the employer’s third-party human resource organization
(e.g., PEO, ASO, HRO) filing on the employer’s behalf.
“Returning Users” refers to EEO-1 Component 1 account holders who had a user account during
a previous reporting year (i.e., cycle).
“Unique Entity ID (UEI)” (ONLY APPLICABLE TO FEDERAL CONTRACTORS) is now the
official identifier for federal contractors. 96 On April 4, 2022, the federal government stopped using
the “Data Universal Numbering System” (DUNS) to uniquely identify entities doing business with
the federal government (i.e., federal contractors). 97
For purposes of the EEO-1 Component 1 data collection, eligible federal contractors will no longer
provide the “DUNS Numbers” associated with their headquarters and/or establishment(s) in the
EEO-1 Component 1 Online Filing System (OFS) or in any data files uploaded to the OFS.
For more information on the federal government’s change to the Unique Entity ID (i.e., UEI), see https://www.gsa.gov/aboutus/organization/federal-acquisition-service/technology-transformation-services/integrated-award-environment-iae/iae-systemsinformation-kit/unique-entity-identifier-update;
https://www.fsd.gov/gsafsd_sp?id=kb_article_view&sysparm_article=KB0041254&sys_kb_id=875189f21bee8d54937fa64ce54b
cbaa&spa=1 and https://sam.gov/content/duns-uei.
97 Before April 4, 2022, the DUNS Number issued by Dun & Bradstreet was the official entity identifier used by the federal
government.
96

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Beginning with the 2022 EEO-1 Component 1 data collection, employers (i.e., singleestablishment and multi-establishment employers) that are federal contractors must instead
provide UEIs generated in SAM.gov. For example, a multi-establishment employer must provide
UEIs for any headquarters and/or establishment(s) which are federal contractors. 98
“Workforce Snapshot Period” refers to the employer-selected pay period used by an employer
for its EEO-1 Component 1 reporting. This pay period must be from the fourth quarter (i.e.,
October 1 through December 31) of the reporting year. Workforce demographic data (i.e.,
employee data by job category and sex and race or ethnicity) must include all full-time and parttime employees who were employed during the pay period selected by the employer. The
workforce snapshot period for the [SPECIFIC REPORTING YEAR FOR EACH COLLECTION
CYCLE WILL BE INSERTED BY EEOC] EEO-1 Component 1 report would be an employerselected pay period between October 1, [SPECIFIC REPORTING YEAR FOR EACH
COLLECTION CYCLE WILL BE INSERTED BY EEOC] and December 31, [SPECIFIC
REPORTING YEAR FOR EACH COLLECTION CYCLE WILL BE INSERTED BY EEOC]. 99
Beginning with the 2023 EEO-1 Component 1 data collection, tentatively scheduled to open in
2024, an employer that meets the employee threshold for EEO-1 Component 1 reporting purposes
at any time during the fourth quarter (i.e., October 1 through December 31) of the reporting year,
may not select a workforce snapshot period where it falls below the threshold in an effort to avoid
the filing requirement.
“Your Employer List” refers to a section in the EEO-1 Component 1 Online Filing System (OFS)
that lists all the employers associated with a user account.

98

Please refer to the above section in the Instruction Booklet entitled “WHO MUST FILE” for federal contractor eligibility.

99 An employer is not required to use the same workforce snapshot period (i.e., months, days) from the fourth quarter of the reporting

year that it selected in previous reporting cycles. For example, an employer that selected a workforce snapshot period with the
month/days of October 1 through October 14 for the 2021 EEO-1 Component 1 reporting cycle may select different month/days
(e.g., November 15 through November 30) for the 2022 EEO-1 Component 1 reporting cycle.

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APPENDIX B
DEFINITIONS OF RACE AND ETHNICITY CATEGORIES 100
Hispanic or Latino
A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture
or origin regardless of race.
White
A person having origins in any of the original peoples of Europe, the Middle East, or North Africa.
Black or African American
A person having origins in any of the black racial groups of Africa.
Native Hawaiian or Other Pacific Islander
A person having origins in any of the peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
Asian
A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian
Subcontinent, including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan,
the Philippine Islands, Thailand, and Vietnam.
American Indian or Alaska Native
A person having origins in any of the original peoples of North and South America (including
Central America), and who maintain tribal affiliation or community attachment.
Two or More Races
All persons who identify with more than one of the above five races (White, Black or African
American, Native Hawaiian or Other Pacific Islander, Asian, American Indian or Alaska Native).
For the purposes of this group, identifying as Hispanic or Latino and only one of the listed 5 race
groups does NOT qualify.
Instructions for Assigning Employees into the Race/Ethnicity Categories
Hispanic or Latino
Include all employees who answer “YES” to the question, “Are you Hispanic or Latino?” in the
appropriate category for both males and females as indicated.

100 OMB is in the process of reviewing and revising its standards for maintaining, collecting, and presenting federal data on race
and
ethnicity.
See
https://www.whitehouse.gov/omb/briefing-room/2022/06/15/reviewing-and-revising-standards-formaintaining-collecting-and-presenting-federal-data-on-race-and-ethnicity/. The EEOC will carefully consider the revision to the
federal standards for collecting race and ethnicity data, which are expected by summer 2024, for use in future data collections.

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White (Not Hispanic or Latino)
Include all employees who identify as White and no other race, and who did not answer “YES” to
the question “Are you Hispanic or Latino?” for both males and females as indicated in the
appropriate category.
Black or African American (Not Hispanic or Latino)
Include all employees who identify as Black or African American and no other race, and who did
not answer “YES” to the question “Are you Hispanic or Latino?” for both males and females as
indicated in the appropriate category.
Native Hawaiian or Other Pacific Islander (Not Hispanic or Latino)
Include all employees who identify as Native Hawaiian or Other Pacific Islander and no other race,
and who did not answer “YES” to the question “Are you Hispanic or Latino?” for both males and
females as indicated in the appropriate category.
Asian (Not Hispanic or Latino)
Include all employees who identify as Asian and no other race, and who did not answer “YES” to
the question “Are you Hispanic or Latino?” for both males and females as indicated in the
appropriate category.
American Indian or Alaska Native (Not Hispanic or Latino)
Include all employees who identify as American Indian or Alaska Native and no other race, and
who did not answer “YES” to the question “Are you Hispanic or Latino?” for both males and
females as indicated in the appropriate category.
Two or More Races (Not Hispanic or Latino)
Include all employees who identify with more than one of the above five races, and who did not
answer “YES” to the question “Are you Hispanic or Latino?” for both males and females as
indicated in the appropriate category.

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APPENDIX C
DESCRIPTION OF JOB CATEGORIES
Executive/Senior Level Officials and Managers 101
Individuals who plan, direct and formulate policies, set strategy and provide the overall direction
of enterprises/organizations for the development and delivery of products or services, within the
parameters approved by boards of directors or other governing bodies. Residing in the highest
levels of organizations, these executives plan, direct or coordinate activities with the support of
subordinate executives and staff managers. They include, in larger organizations, those individuals
within two reporting levels of the CEO, whose responsibilities require frequent interaction with
the CEO.
Examples: chief executive officers; chief operating officers; chief financial officers; line of
business heads; presidents or executive vice presidents of functional areas or operating groups;
chief information officers; chief human resources officers; chief marketing officers; chief legal
officers; management directors and managing partners.
First/Mid-Level Officials and Managers 102
Individuals who serve as managers, other than those who serve as Executive/Senior Level Officials
and Managers, including those who oversee and direct the delivery of products, services or
functions at group, regional or divisional levels of organizations. These managers receive
directions from the Executive/Senior Level management and typically lead major business units.
They implement policies, programs and directives of executive/senior management through
subordinate managers and within the parameters set by Executive/Senior Level management.
Examples: vice presidents and directors; group, regional or divisional controllers; treasurers;
human resources, information systems, marketing, and operations managers.
The “First/Mid-Level Officials and Managers” subcategory also includes those who report directly
to middle managers. These individuals serve at functional, line of business segment or branch
levels and are responsible for directing and executing the day-to-day operational objectives of
enterprises/organizations, conveying the directions of higher-level officials and managers to
subordinate personnel and, in some instances, directly supervising the activities of exempt and
non-exempt personnel.

The “Officials and Managers” category as a whole is to be divided into the following two subcategories: “Executive/Senior Level
Officials and Managers,” and “First/Mid-Level” Officials and Managers.” These subcategories are intended to mirror the
employer’s own well-established hierarchy of management positions. Small employers who may not have two well-defined
hierarchical steps of management should report their management employees in the appropriate categories.
102 The “Officials and Managers” category as a whole is to be divided into the following two subcategories: “Executive/Senior Level
Officials and Managers,” and “First/Mid-Level” Officials and Managers.” These subcategories are intended to mirror the
employer’s own well-established hierarchy of management positions. Small employers who may not have two well-defined
hierarchical steps of management should report their management employees in the appropriate categories.
101

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Examples: first-line managers; team managers; unit managers; operations and production mangers;
branch managers; administrative services managers; purchasing and transportation managers;
storage and distribution managers; call center or customer service managers; technical support
managers; and brand or product managers.
Professionals
Most jobs in this category require bachelor and graduate degrees, and/or professional certification.
In some instances, comparable experience may establish a person’s qualifications.
Examples: accountants and auditors; airplane pilots and flight engineers; architects; artists;
chemists; computer programmers; designers; dieticians; editors; engineers; lawyers; librarians;
mathematical scientists; natural scientists; registered nurses; physical scientists; physicians and
surgeons; social scientists; teachers; and surveyors.
Technicians
Jobs in this category include activities that require applied scientific skills, usually obtained by
post-secondary education of varying lengths, depending on the particular occupation, recognizing
that in some instances additional training, certification, or comparable experience is required.
Examples: drafters; emergency medical technicians; chemical technicians; and broadcast and
sound engineering technicians.
Sales Workers
These jobs include non-managerial activities that wholly and primarily involve direct sales.
Examples: advertising sales agents; insurance sales agents; real estate brokers and sales agents;
wholesale sales representatives; securities, commodities, and financial services sales agents;
telemarketers; demonstrators; retail salespersons; counter and rental clerks; and cashiers.
Administrative Support Workers
These jobs involve non-managerial tasks providing administrative and support assistance,
primarily in office settings.
Examples: office and administrative support workers; bookkeepers; accounting and auditing
clerks; cargo and freight agents; dispatchers; couriers; data entry keyers; computer operators;
shipping, receiving and traffic clerks; word processors and typists; proofreaders; desktop
publishers; and general office clerks.
Craft Workers
Most jobs in this category include higher skilled occupations in construction (building trades craft
workers and their formal apprentices) and natural resource extraction workers.
Examples: boilermakers; brick and stone masons; carpenters; electricians; painters (both
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construction and maintenance); glaziers; pipe layers, plumbers, pipefitters and steamfitters;
plasterers; roofers; elevator installers; earth drillers; derrick operators; oil and gas rotary drill
operators; and blasters and explosive workers.
This category also includes occupations related to the installation, maintenance and part
replacement of equipment, machines and tools.
Examples: automotive mechanics; aircraft mechanics; and electric and electronic equipment
repairers.
This category also includes some production occupations that are distinguished by the high degree
of skill and precision required to perform them, based on clearly defined task specifications.
Examples: millwrights; etchers and engravers; tool and die makers; and pattern makers.
Operatives
Most jobs in this category include intermediate skilled occupations and include workers who
operate machines or factory-related processing equipment. Most of these occupations do not
usually require more than several months of training.
Examples: textile machine workers; laundry and dry-cleaning workers; photographic process
workers; weaving machine operators; electrical and electronic equipment assemblers;
semiconductor processors; testers, graders and sorters; bakers; and butchers and other meat,
poultry and fish processing workers.
This category also includes occupations of generally intermediate skill levels that are concerned
with operating and controlling equipment to facilitate the movement of people or materials.
Examples: bridge and lock tenders; truck, bus or taxi drivers; industrial truck and tractor (forklift)
operators; parking lot attendants; sailors; conveyor operators; and hand packers and packagers.
Laborers and Helpers
Jobs in this category include workers with more limited skills who require only brief training to
perform tasks that require little or no independent judgment.
Examples: production and construction worker helpers; vehicle and equipment cleaners; laborers;
freight, stock and material movers; service station attendants; construction laborers; refuse and
recyclable materials collectors; septic tank servicers; and sewer pipe cleaners.
Service Workers
Jobs in this category include food service, cleaning service, personal service, and protective service
activities. Skill may be acquired through formal training, job-related training or direct experience.
Examples (Food Service): cooks; bartenders; and other food service workers.

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Examples (Personal Service): medical assistants and other healthcare support positions;
hairdressers; ushers; and transportation attendants.
Examples (Cleaning Service): cleaners; janitors; and porters.
Examples (Protective Service): transit and railroad police and fire fighters; guards; private
detectives and investigators.

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APPENDIX D
ADDITIONAL RESPONSIBILITIES OF THIRD-PARTY HUMAN RESOURCE
ORGANIZATIONS AND THEIR CLIENT EMPLOYERS
The purpose of this appendix is to provide additional information on the filing responsibilities of
third-party human resource organizations (e.g., Professional Employer Organizations (PEOs),
Administrative Services Organizations (ASOs), Human Resource Outsourcing organizations
(HROs)) and their client employers. 103
Reports Required for Filing on Behalf of a Client Employer
Third-party human resource organizations (e.g., PEOs, HROs, ASOs) are not permitted to file for
an eligible client employer as an “establishment” of the third-party human resource organization.
In other words, a third-party human resource organization may not submit an EEO-1 Component
1 report that includes itself and a client employer or a report that includes multiple client employers.
Additionally, third-party human resource organizations (e.g., PEOs, HROs, ASOs) are not
permitted to file only establishment report(s) for a client employer. Third-party human resource
organizations choosing to file on behalf of a single-establishment client employer (i.e., singleestablishment employer) or a multi-establishment client employer (i.e., multi-establishment
employer) must file all the reports that a client employer filing on its own behalf would be required
to file.
A third-party human resource organization (e.g., PEO, HRO, ASO) is also not permitted to file
EEO-1 Component 1 report(s) on behalf of a client employer for only a partial number of the client
employer’s employees. In such a situation, the client employer, not the third-party human resource
organization, must file EEO-1 Component 1 report(s) for all its employees.
Single-Establishment Client Employer (i.e., single-establishment employer)
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to file on behalf of a
single-establishment client employer (i.e., single-establishment employer) must file the following
report under the client employer’s own EEO-1 Component 1 Online Filing System (OFS) employer
registration.
Single-Establishment Employer Report 104
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to file on
behalf of a single-establishment client employer (i.e., single-establishment employer),
must submit one EEO-1 Component 1 report (i.e., “Single-Establishment Employer
Clients of Professional Employer Organizations (PEOs), Administrative Services Organizations (ASOs), Human Resource
Outsourcing organizations (HROs), and similar third-party human resource organizations are referred to as “client employers” by
the EEOC for purposes of the EEO-1 Component 1 data collection. A “client employer” is an employer that uses the services of a
third-party human resource organization (e.g., PEO, HRO, ASO). These services can include preparing and filing the employer’s
EEO-1 Component 1 report(s) on the employer’s behalf. The employer using these services is referred to as a “client employer” of
the third-party human resource organization (e.g., PEO, HRO, ASO) that is filing on the employer’s behalf.
104 The “Single-Establishment Employer Report” was formerly referred to as a “Type 1” report. Beginning with the 2022 EEO-1
Component 1 data collection, this report is now known as a “Single-Establishment Employer Report.”
103

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Report”) for a single-establishment client employer conducting business or performing
services or industrial operations at only one establishment. This report is referred to as a
“Single-Establishment Employer Report.” The Single-Establishment Employer Report
must include demographic data for all the single-establishment client employer’s
employees categorized by job category and sex and race or ethnicity.
A third-party human resource organization (e.g., PEO, HRO, ASO) is not permitted to
certify a client employer’s “Single-Establishment Employer Report” (i.e., EEO-1
Component 1 report). An official (i.e., employee) of the client employer (i.e., “Certifying
Official”) must certify the client employer’s “Single-Establishment Employer Report” (i.e.,
EEO-1 Component 1 report.) The client employer’s “Certifying Official” cannot be from
the third-party human resource organization (e.g., PEO, HRO, ASO).
Multi-Establishment Client Employer (i.e., multi-establishment employer) 105
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to file on
behalf of a multi-establishment client employer (i.e., multi-establishment employer) must
file the following reports under the client employer’s own EEO-1 Component 1 Online
Filing System (OFS) employer registration.
Headquarters Report 106
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to file on
behalf of a multi-establishment client employer (i.e., a multi-establishment employer),
must submit a “Headquarters Report” for the multi-establishment client employer. The
“Headquarters Report” must include demographic data for all the multi-establishment
client employer’s employees at its headquarters (i.e., main office site), as well as any
remote employees who report to the employer’s headquarters, categorized by job category
and sex and race or ethnicity. 107
Establishment-Level Report 108
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to file on
behalf of a multi-establishment client employer (i.e., a multi-establishment employer),
must submit an “Establishment-Level Report” for each non-headquarters establishment of
the client employer regardless of the number of employees at the establishment. The
“Establishment-Level Report” must include demographic data for all the multiestablishment employer’s employees at each establishment, as well as any remote
A multi-establishment client employer (i.e., multi-establishment employer) is an employer conducting business or performing
services or industrial operations at more than one establishment. A multi-establishment employer is required to submit and certify
all the following three types of EEO-1 Component 1 reports (i.e., “Consolidated Report”; “Headquarters Report”; “EstablishmentLevel Report(s)”). Multi-establishment employers, including, for example, parent corporations and their subsidiary holdings, must
report demographic workforce data for all employees at each establishment(s) and subsidiary establishment(s).
106 The “Headquarters Report” was formerly referred to as a “Type 3” headquarters report. Beginning with the 2022 EEO-1
Component 1 data collection, this report is now known simply as a “Headquarters Report.”
107 A “Headquarters Report” must be submitted even if there are fewer than 50 employees working at and/or reporting to the
headquarters location.
108 The “Establishment-Level Report” encompasses the former “Type 4” report for establishments with 50 or more employees and
the former “Type 8” report for establishments with fewer than 50 employees. Beginning with the 2022 EEO-1 Component 1 data
collection, the “Type 4” report and “Type 8” report have been discontinued. These reports have been replaced with the
“Establishment-Level Report.”
105

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employees who report to the establishment, categorized by job category and sex and race
or ethnicity. 109
Consolidated Report 110
A third-party human resource organization (e.g., PEO, HRO, ASO) choosing to file on
behalf of a multi-establishment client employer (i.e., multi-establishment employer), must
submit a “Consolidated Report” for the multi-establishment client employer. The
Consolidated Report must include demographic data for all the multi-establishment client
employer’s employees (i.e., all employees at the employer’s headquarters as well as all
establishments) categorized by job category and sex and race or ethnicity. In other words,
the total number of employees contained in the client employer’s “Headquarters Report”
plus the total number of employees contained in all the client employer’s “EstablishmentLevel Report(s)” must equal the total number of employees contained in the “Consolidated
Report.”
With the discontinuation of the “Type 6” establishment list report, 111 a “Consolidated
Report” is now auto-populated and auto-generated with data from a multi-establishment
client employer’s “Headquarters Report” and “Establishment-Level Report(s)” within the
EEOC’s electronic, web-based EEO-1 Component 1 Online Filing System (OFS) for all
multi-establishment employers.
Although a “Consolidated Report” is now auto-populated and auto-generated, a multiestablishment employer is still responsible for ensuring that the total employee count in the
“Consolidated Report” matches the total number of employees the filer is reporting in its
“Headquarters Report” and “Establishment-Level Report(s)” prior to certification. An
employer must also ensure that it has reported for all its establishments. For example, if an
employer has 200 establishments, but only reported data for 150 establishments, the
“Consolidated Report” will only reflect the data for establishments submitted by the filer
(i.e., 150). It is the responsibility of the employer to ensure that data for each of its
establishments has been submitted and that the “Consolidated Report” matches that
number. 112
The EEOC has discontinued the option to use a “Type 6” establishment list report for establishments with fewer than 50
employees. All multi-establishment employers must instead submit an “Establishment-Level Report” for each non-headquarters
establishment regardless of the number of employees at the establishment (e.g., fewer than 50 or more than 50).
110 The “Consolidated Report” was formerly referred to as a “Type 2” consolidated report. Beginning with the 2022 EEO-1
Component 1 data collection, this report is now known simply as a “Consolidated Report.”
111 The prior “Type 6” establishment list report contained the name and address of each non-headquarters establishment with fewer
than 50 employees, as well as the total number of employees at each establishment. A multi-establishment employer choosing the
option to submit a “Type 6” establishment list report, instead of a “Type 8” report, was required to manually enter employee
demographic data by job category and sex and race or ethnicity into the accompanying “Type 2” consolidated report for every
employee of every establishment included on the “Type 6” establishment list report.
112 As discussed in the above section of the Instruction Book entitled “REPORTING BY SEX,” the EEO-1 Component 1 data
collection currently provides only binary options (i.e., male or female) for reporting employee counts by sex, job category, and race
or ethnicity. However, employers may voluntarily choose to report employee demographic data for non-binary employees – that
is, employees who do not identify as exclusively male or female – by sex (i.e., non-binary), job category and race or ethnicity in
the “comments” section of the report(s). Employers that voluntarily choose to report non-binary employees in the “comments”
section of the report(s) should not assign such employees to the male or female categories or any other categories (i.e., job category
and race or ethnicity) within the report(s). For additional information on the voluntary reporting of non-binary employees, please
refer to the above section of the Instruction Booklet entitled “REPORTING BY SEX.”
109

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Additionally, a third-party human resource organization (e.g., PEO, HRO, ASO) is not
permitted to certify a multi-establishment client employer’s EEO-1 Component 1 report (i.e.,
“Consolidated Report,” “Headquarters Report,” “Establishment-Level Report(s)”). An
official (i.e., employee) of the client employer (i.e., “Certifying Official”) must certify the
client employer’s EEO-1 Component 1 report(s). The client employer’s “Certifying
Official” cannot be from the third-party human resource organization (e.g., PEO, HRO,
ASO).
EIN and NAICS Code Required for Filing on Behalf of a Client Employer
Every eligible client employer on behalf of which a third-party human resource organization (e.g.,
PEO, HRO, ASO) chooses to file will be required to have its own employer registration record
under the client employer’s EIN (Employer Identification Number) within the EEO-1 Component
1 Online Filing System (OFS). Additionally, all client employers and third-party human resource
organizations (e.g., PEOs, HROs, ASOs) are required to have a user account to gain access to the
EEO-1 Component 1 Online Filing System (OFS).
The employer registration record must be for the client employer itself and not the third-party
human resource organization (e.g., PEO, HRO, ASO) filing on the client employer’s behalf.
Additionally, the NAICS code for the client employer and each of its establishments must be based
on the major business activity at each of the client employer’s establishment(s) as well as the
appropriate EIN for each of the client employer’s establishment(s). The third-party human resource
organization (e.g., PEO) is not permitted to use its own NAICS code (e.g., 561330 – Professional
Employer Organizations) or the third-party human resource organization’s EIN (e.g., PEO’s EIN,
HRO’s EIN, ASO’s EIN) on the client employer’s reports (i.e., “Single-Establishment Employer
Report,” “Consolidated Report,” “Headquarters Report,” “Establishment-Level Report(s)”).
Filing for Only Eligible Client Employers
If a client employer of a third-party human resource organization (e.g., PEO, HRO, ASO) is not
otherwise subject to the EEO-1 Component 1 filing requirements, that client employer is not
required to file an EEO-1 Component 1 report(s) simply by virtue of being a client of a third-party
human resource organization (e.g., PEO, HRO, ASO).
For example, a single-establishment client employer with only 40 employees would not meet the
eligibility thresholds requiring it to file an EEO-1 Component 1 report. Thus, neither the client
employer nor its PEO would be required to report the client employer’s employees for purposes of
EEO-1 Component 1 reporting.
Reporting Considerations for a Client Employer Using a Third-Party Human Resource
Organization EIN
If a client employer uses a third-party human resource organization’s (e.g., HRO) EIN for payroll
purposes and the client employer is not otherwise subject to the EEO-1 Component 1 filing

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requirements, that client employer is not required to file an EEO-1 Component 1 report(s) simply
by virtue of being a client of a third-party human resource organization (e.g., HRO) and/or using
the organization’s EIN for payroll purposes. For example, a single-establishment client employer
with only 40 employees that uses a HRO’s EIN for payroll purposes would not meet the eligibility
thresholds requiring it to file an EEO-1 Component 1 report.
Alternatively, if a client employer meets the EEO-1 Component 1 eligibility requirements, then
the client employer is required to submit an EEO-1 Component 1 report(s). The EEO-1 Component
1 report(s) filed by a client employer, or on behalf of a client employer by a third-party human
resource organization (e.g., HRO), must include all the client employer’s employees, even if some
or all of those employees were paid under the third-party human resource organization’s (e.g.,
HRO) EIN.
Reporting by an ASO (Administrative Services Organization)
An ASO is permitted to link multiple client employers to an individual user account created by the
ASO within the EEO-1 Component 1 Online Filing System (OFS). However, every eligible client
employer on behalf of which a third-party human resource organization (e.g., ASO) chooses to file
is required to have its own employer registration record under the client employer’s EIN (i.e.,
Employer Identification Number) within the EEO-1 Component 1 Online Filing System (OFS).
This employer registration record must be for the client employer itself and not the third-party
human resource organization (e.g., PEO, HRO) filing on the client employer’s behalf.
Additionally, all client employers, as well as all third-party human resource organizations filing
on behalf of client employers, are required to have a user account to gain access to the EEO-1
Component 1 Online Filing System (OFS).
Considerations for Current and Former Client Employers of Third-Party Human Resource
Organizations
The EEOC cannot provide current or former client employers of a third-party human resource
organization with any prior year EEO-1 Component 1 report(s) filed on their behalf by a thirdparty human resource organization (e.g., PEO, HRO, ASO). Current or former client employers
for which a third-party human resource organization (e.g., PEO, HRO, ASO) filed historical EEO1 Component 1 data on the client employers’ behalf must contact their third-party human resource
organization (e.g., PEO, HRO, ASO) to obtain any such reports.
If a client employer has changed its third-party human resource organization (e.g., PEO, HRO,
ASO), it is the responsibility of the client employer to determine which third-party human resource
organization (e.g., PEO, HRO, ASO) is choosing to prepare and file the client employer’s EEO-1
Component 1 report(s) on its behalf. It is also the responsibility of the client employer to ensure a
an EEO-1 Component 1 report(s) is filed its behalf. If a third-party human resource organization
(e.g., PEO, HRO, ASO) is choosing to prepare and file a client employer’s EEO-1 Component 1
report(s), the client employer should contact the third-party human resource organization to ensure
it has the necessary information to file.
It is the responsibility of a client employer and/or former client employer to ensure an EEO-1
Component 1 report(s) is filed with the EEOC. If neither a former nor current third-party human
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resource organization (e.g., PEO, HRO, ASO) is choosing to prepare and file EEO-1 Component
1 report(s) on a client employer’s behalf, the client employer is still required to have its own
employer registration record under the client employer’s EIN (i.e., Employer Identification
Number) within the EEO-1 Component 1 Online Filing System (OFS).

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APPENDIX E
SAMPLE EEO-1 COMPONENT 1 REPORT

NOTICE: SAMPLE EEO-1 COMPONENT 1 REPORT
As discussed in the 30-day Notice published in the Federal Register on May
2, 2023, the EEOC created the Office of Enterprise Data and Analytics
(OEDA) in May 2018 with the goal of creating a modern data and analytics
organization at the agency. Since its creation, OEDA, which administers the
agency’s EEO data collections, including the EEO-1 Component 1, has
worked to modernize the collections and improve the quality of data collected.
OEDA has also streamlined functions, such as providing additional selfservice options, resource materials, and an online support message center.
As part of its ongoing modernization efforts and in response to feedback from
filers in prior collections, OEDA has redesigned the format of the certified
report(s) generated by the EEO-1 Component 1 Online Filing System (OFS).
The report(s), which filers will be able to download and save as a PDF, contain
several enhancements to how information provided by filers is displayed. For
example, the updated report(s) now have delineated sections and headers that
clearly identify the information being displayed and filers’ answers to
reporting questions such as eligibility and federal contractor status.
Please Note: This is a “sample” EEO-1 Component 1 report generated by the
EEOC’s EEO-1 Component 1 Online Filing System (OFS). Filers are not
permitted to submit EEO-1 Component 1 workforce demographic data using
this sample. The EEOC requires electronic submission of EEO-1 Component
1 report(s) through the OFS, the agency’s web-based data collection
application (i.e., portal). The OFS is accessible at www.eeocdata.org/eeo1.
The EEOC will only accept EEO-1 Component 1 report(s) submitted and
certified through the OFS. The EEOC will not accept reports submitted via
paper or through other non-OFS electronic means (e.g., email, CD-ROM). The
EEOC will consider filers submitting reports outside of the OFS to be noncompliant for purposes of their mandatory EEO-1 Component 1 filing
obligation.

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