Recordkeeping and Reporting Requirements Under Title VII, the ADA, GINA, and the PWFA
Published Date: 1/10/2025
Rule
Summary
Starting January 10, 2025, the EEOC is updating how employers handle recordkeeping and reporting under key civil rights laws like Title VII and the ADA. Now, the Chief Data Officer will decide on hardship exemption requests using clear steps and criteria, making the process smoother. This change affects all employers who submit Equal Employment Opportunity reports and aims to save time without adding extra costs.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
Unified Exemption Process; CDO Decides
Starting January 10, 2025, the EEOC replaces multiple, separate undue-hardship rules with one new subpart that applies to all EEO reports. The rule delegates to the Commission's Chief Data Officer (CDO) (or the CDO's designee) the authority to decide exemption applications and requires the CDO to issue written determinations.
Keep Preparing Data While Exemption Pending
If you apply for an exemption, you must keep collecting and preparing the required EEO report data while the exemption request is pending. The rule explicitly requires filers to continue data collection in case the exemption is denied.
Denial Gives 30+ Day Filing Deadline; Right to Sue
If the CDO denies an exemption, the CDO must notify the filer in writing and set a deadline of at least 30 calendar days after the denial to file the report. The notice must also inform the filer they may bring a civil action in U.S. District Court under 42 U.S.C. 2000e-8(c).
No New Paperwork; Limited Small-Entity Impact
The EEOC states this final rule imposes no new information-collection requirements under the Paperwork Reduction Act and "will not have a significant economic impact on a substantial number of small entities" under the Regulatory Flexibility Act. The rule is described as clarifying the exemption request process rather than creating new burdens.
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