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EEOC issues clarification on EEO-1 “client site” confusion

What address should employers use to report off-site employees?

Posted February 28, 2018

With the new March 31 deadline looming, many employers pushing to complete their required EEO-1 reports may find themselves confused about how to report employees who “regularly report” to client sites rather than an employer location, such as contractors, consultants, or construction workers. Should they list the employees’ reporting address as the company headquarters, where they are officially employed, or should they list the client address, where the majority of their work occurs?

To alleviate the confusion, the EEOC released the following statement:

“It has come to the EEOC’s attention that there may be some confusion as to how employers are to report employees working at client sites. Some employers have been reporting the address of client sites for employees, while other employers have instead been rolling those employees up to a non-client site employer address. Given this confusion, employers will not be considered ‘non-compliant’ if they have chosen one approach over the other - either reporting by client site or by non-client site employer address. EEOC is considering how to address client site reporting.”

This guidance will likely come as good news, both to employers who have already filed the 2018 report but may have had questions, as well as to those still working to compile the data.

This article was written by Ann Potratz of J. J. Keller & Associates, Inc.

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