The September 30, 2019, deadline for filing EEO-1 Component 2 pay data reports is just a few days away. The Component 2 filing requirement came from the U.S. District Court for the District of Columbia in an order issued by Judge Tanya S. Chutkan on April 25, 2019, that jump-started the rush to the September 30 deadline.

While the Equal Employment Opportunity Commission (EEOC) contemplated the Component 2 filings in 2016, the filing process was not fully developed before the Trump administration postponed it. Since Judge Chutkan reinstated the pay data filing requirement and imposed the September 30 deadline, the path forward has been rocky. The EEOC has contr