Multi-establishment employers who take advantage of the EEOC’s Special Procedures do so to better align their data with the realities of their organizational structure. According to the FAQs and EEO-1 Instruction Booklet multi-establishment employers must follow special procedures when:
EEO-1 Frequently Asked Questions (FAQs)
If the establishments that are located at the same address AND have the same NAICS code and the same FEIN, the establishments MUST be combined into only one report. If your company is unable to combine these records due to corporate structure, please consult Item #5 “Requests for Information and Special Procedures” found in the EEO-1 Instruction Booklet.
EEO-1 Instruction Booklet
5. REQUESTS FOR INFORMATION AND SPECIAL PROCEDURES
An employer who claims that preparation or the filing of Standard Form 100 would create undue hardship may apply to the Commission for a special reporting procedure. In such cases, the employer must submit, in writing, a detailed alternative proposal for compiling and reporting information to:
The EEO-1 Coordinator
1801 L Street, NW
Washington, DC 20507
Only those special procedures approved in writing by the Commission are authorized. Such authorizations remain in effect until notification of cancellation is given. All requests for information should be sent to the address above.
However, Biddle has received clarification from the EEO-1 Joint Reporting Committee indicating that contractors do not need to follow special reporting procedures when an address and NAICS are the same but the FEIN is different.
- Establishments located at the same address, with the same NAICS and the same FEIN must file for Special Procedures to submit those establishments separately
- Establishments located at the same address, with the same NAICS and different FEINs are able to submit without seeking special procedural relief.
- Employers that have a combination of both must seek relief through Special Procedures.
If you have questions regarding EEO-1 submittal or need assistance, please feel free to contact Biddle Consulting Group’s EEO/AA Department.