Federal Contractor Reports to File in 2024

EEO-1 Report: Due June 4, 2024 (Date Subject to Change)

The Equal Employment Opportunity Commission (EEOC) has not yet announced the 2023 EEO-1 data collection Portal will opening date (Update: April 30, 2024). However, the traditional due date is March 31. Employers can access the dedicated online portal for this submission at EEOCdata.org/eeo1. For companies looking for guidance, the updated instruction booklet for the most recent cycle titled “2022 EEO-1 Component 1 Instruction Booklet” is available.

California Pay Data Reports: Due May 8, 2024

The deadline for submitting the 2022 California Pay Data Report is May 8, 2024. Employers can submit their reports electronically through the California Department of Fair Employment and Housing’s (DFEH) online filing system.

What Information is Required for the California Pay Data Report?
- The California Pay Data Report requires employers to submit the following information:

1. Pay Data: Employers must report the number of employees by race, ethnicity, and gender in each of the ten EEO-1 Job Categories. This data should be collected from a single pay period between October 1st and December 31st of the previous year, known as the “Snapshot Period.”
2. Compensation Bands: Employers must report the number of employees in each pay band, based on the W-2 Box 5 wages.
3. Hours Worked: Employers must report the total hours worked by each employee within each pay band, race, ethnicity, and gender group. This includes hours worked by exempt, non-exempt, full-time, and part-time employees.
4. Effective January 1, 2023, Senate Bill 1162 requires that all Payroll Employee Reports include the mean and median hourly rate of all groupings of employees with the same establishment, job category, race/ethnicity, and sex.

What Information is Required for the California Pay Data Labor Contract Employee Report?

The California Pay Data Labor Contract Employee Report requires employers to submit the following information (Government Code section 12999(a)(2) requires labor contractors to supply all necessary data to any client employer obligated to file a Labor Contractor Employee Report, and Government Code section 12999(f) permits any civil penalty to be awarded against a client employer for failure to file its report to be proportionally assessed against a labor contractor that failed to provide necessary data to that client employer.):

1. Pay Data: Employers must report the number of labor contract employees by race, ethnicity, and gender in each of the ten EEO-1 Job Categories. This data should be collected from a single pay period between October 1st and December 31st of the previous year, known as the “Snapshot Period.”
2. Compensation Bands: Employers must report the number of labor contract employees in each pay band, based on the W-2 Box 5 wages. If a labor contract employee has worked for more than one client employer over the course of the calendar year, their W-2 Box 5 wages should be allocated respectively to each client employer.
3. Hours Worked: Employers must report the total hours worked by each labor contract employee within each pay band, race, ethnicity, and gender group. If a labor contractor employee has worked for more than one client employer over the course of the calendar year, their hours worked should be allocated respectively to each client employer, based on the hours of work performed for that client employer.
4. Effective January 1, 2023, Senate Bill 1162 requires that all Labor Contractor Employee Reports include the mean and median hourly rate of all groupings of employees with the same establishment, job category, race/ethnicity, and sex.

OFCCP Contractor Portal Certification: April 1 – July 1, 2024 (Dates subject to change)

The Office of Federal Contract Compliance Programs (OFCCP) Contractor Portal Certification is an annual requirement for federal contractors and subcontractors who are subject to nondiscrimination requirements and responsible for developing written affirmative action plans. The certification process requires contractors to log into the OFCCP’s secure online portal and certify that they have developed written affirmative action plan(s) and are in compliance with the regulations by July 1, 2024.

Contractors who neglect to certify by the July 1 deadline may face a higher likelihood of appearing on the OFCCP’s audit scheduling list, which some would consider unappealing scrutiny. Starting in January 2023, OFCCP began targeting companies that failed to certify in 2022.

Vets-4212 Report

The Vets-4212 reporting deadline, September 30, will be here before you know it. All nonexempt Federal contractors and subcontractors with a contract or subcontract in the amount of $150,000 or more with any department or agency of the United States for the procurement of personal property or non-personal services are required to file a Vets-4212 report. You can find the online filing system at: Vets4212.dol.gov/vets4212.