You have no doubt heard that the Equal Employment Opportunity Commission proposes to require employers with 100 or more employees to start submitting compensation data with their annual EEO-1 reports.
The proposal was announced by President Obama in a White House ceremony last week celebrating the seventh anniversary of the Lilly Ledbetter Fair Pay Act. Here’s the scoop.
The proposal could certainly have been worse. The EEOC would require the reporting to occur at the same time that employers already do their EEO-1 reporting (efficient!), proposes the use of W-2 earnings data (efficient and easy!), proposes that the survey will replace rather than supplement the proposed pay survey rule issued by the Office of Federal Contract Compliance Programs that would have applied to federal contractors (only one rule to worry about instead of two!), and proposes to delay the effective date until Fiscal Year 2017 (never do today what you can put off until tomorrow!).
All that having been said, I’m against it. Here’s why.