The U.S. Equal Employment Opportunity Commission (EEOC) officially opened its annual workplace demographic data collection window today, reminding employers of their legal obligations under Title VII and cautioning against using protected characteristics such as race or sex as a basis for employment decisions in the name of diversity.
The data collection period for EEO-1 Component 1 reports runs from May 20 through June 24, 2025. Private employers with 100 or more employees, and certain federal contractors with at least 50 employees, are required to submit demographic workforce data by job category, race, ethnicity, and sex for a designated pay period within October to December of the reporting year.
In a statement posted to the EEOC’s data collection website, Acting Chair Andrea Lucas emphasized that Title VII’s protections apply equally to all individuals and warned: “There is no ‘diversity’ exception to Title VII’s requirements.”
Lucas continued, “As you report data on your employees’ race, ethnicity, and sex, I urge employers to remember that employment actions cannot be motivated by protected characteristics. Such actions can constitute unlawful discrimination, regardless of intent.”
The agency’s warning comes amid broader federal policy shifts. Lucas noted the EEOC’s alignment with President Donald Trump’s executive order, “Restoring Equality of Opportunity and Meritocracy,” which directs agencies to de-emphasize enforcement based on disparate impact theory. “Under my leadership, the EEOC will prioritize remedying intentional discrimination claims,” she added.
The EEOC also announced changes to its EEO-1 instruction booklet following approval from the Office of Management and Budget (OMB). Updates include:
