SHRM Urges EEOC to Modernize EEO Reporting Requirements

SHRM is urging the U.S. Equal Employment Opportunity Commission (EEOC) not to simply eliminate longstanding workforce demographic reporting requirements without replacing them with a modernized framework that gives employers clear guidance on collecting and using such data.

The EEOC voted in July to propose rescinding the EEO-1 through EEO-6 reporting requirements, along with related recordkeeping requirements. The reports require covered entities to submit aggregate workforce data on race and sex. The agency estimates its current data-collection requirements cost employers nearly $275 million annually. The proposal remains in the rulemaking process and has not yet become a final rule.

In comments submitted to the EEOC Aug. 24, SHRM said it supports reducing unnecessary regulatory burdens but cautioned that demographic information remains valuable for both employers and regulators.

“Workforce demographic data remains an important tool for employers and the EEOC,” the association said. “However, the current EEO reporting framework no longer reflects today's workforce or employer needs.” Accordingly, SHRM said it supports rescinding the existing requirements “only if they are replaced with a modernized framework that produces more accurate, meaningful, and actionable guidance regarding workforce demographic data collection.”

HR Q&A: What Is the EEO-1 Component 1 Data Report 

Rescission Could Create New Uncertainty

The EEO reporting system has provided employers with a common federal reference point for nearly six decades. SHRM warned that eliminating it without an alternative could leave employers uncertain about what demographic information they should collect, how long they should retain it, who should have access and how it may lawfully be used.

Those questions would not disappear with the reporting mandate. Employers would remain subject to federal, state, and local recordkeeping, in addition to equal-pay and nondiscrimination requirements, some of which rely on demographic information or existing EEO-1 categories. Multistate employers could consequently face an increasingly fragmented collection of requirements without a federal benchmark.

Demographic data also remains useful in compliance reviews and discrimination litigation. Employers may use it to evaluate employment practices, investigate disparities and respond to agency inquiries or claims involving disparate impact or disparate treatment.

SHRM research underscores that distinction. In 2026, 59% of HR professionals identified pay or compensation data and 53% identified workforce demographic information as among the information most necessary for nondiscrimination compliance. Sixty percent said organizations should use demographic data to evaluate recruiting, hiring and promotion practices, while another 60% supported using it to identify and proactively address workforce trends or disparities.

At the same time, employers appear considerably less enthusiastic about the existing reporting mechanism. Among organizations subject to mandatory demographic reporting, 22% said the data was “not at all useful” for supporting compliance and workforce analysis, while 35% called it “not very useful.” Just 6% considered it very useful.

Toolkit: SHRM’s BEAM Toolkit for I&D    

A Push for Modernization

Rather than preserving the existing system unchanged, SHRM encourages the EEOC to develop a purpose-driven framework accompanied by technical assistance explaining appropriate data collection, access, retention, analysis, and use.

“The goal should be better data, not simply more data or less data,” SHRM said.

Ultimately, SHRM views the proposed rescission as an opportunity for modernization rather than abandonment of workforce demographic data.  

“Rescinding the current reporting requirements should be an opportunity to build something better,” the association concluded, “not an invitation to abandon the underlying value of workforce demographic data.”