Navigating today’s constantly evolving compliance landscape can be challenging. To help simplify the process, Berkshire has compiled an overview of key federal and state EEO reporting deadlines and thresholds, giving you the clarity and confidence needed to stay compliant and avoid costly missteps. If you’d like expert support with any of these reporting obligations, our team is ready to help—contact us today.
Federal Government EEO Reporting Obligations
EEO-1: Required for private Employers with 100 or more employees. Federal Contractors with 50-99 employees were required to file last year despite the revocation of Executive Order 11246. The threshold for federal contractors may change in 2026 (2025 workforce data) but there is no update on this as of February 2026. Pertinent data requirements include establishment information, race/sex of employees, and job category information.
VETS-4212: Required for federal contractors, the current portal still lists $150,000 as the threshold but we anticipate that being updated to $200,000 for the 2026 cycle. Pertinent data requirements included establishment information, veteran status of the roster and new hires, as well as minimum/maximum employee counts, by job categories.
Section 503 Non-Discrimination Plan: Required for federal contractors that have contracts of $50,000 or more. Pertinent data includes analysis of roster and other personnel actions to complete required data reporting. Also requires designated outreach and recruitment and evaluations of those strategies.
VEVRAA Non-Discrimination Plan: Required for federal contractors that have contracts of $200,000 or more. Pertinent data includes analysis of roster and other personnel actions to complete required data reporting. Also requires designated outreach and recruitment and evaluations of those strategies.
OFCCP Certification Portal: The OFCCP Certification portal was used to certify compliance with annual affirmative action obligations until Executive Order 11246 was revoked. No certification was required in 2025, but the portal remains operational and a modified certification requirement could be put in place.
Common State EEO Reporting Obligations
California Payroll Employee Reporting: Required annually for private employers who have 100 employees or more with at least one in California. Pertinent data requirements include establishment information, employee demographics by race/sex and job category, and additional employee status and pay data.
California Labor Contractor Reporting: Required annually for private employers who have 100 labor contractors or more with at least one in California. Pertinent data requirements included establishment information, labor contractor demographics by race/sex and job category, and additional labor contractor status and pay data. This report requires active participation from the labor contractor itself to provide the needed information.
IL Equal Pay Reporting: Required for employees with100 or more employees in Illinois. Pertinent data requirements include employee level race/sex demographics by job category, as well as pay data. This report is filed biennially (once every two years), not once a year like most government reports.
MA State Reporting: Required for private employers with 100 or more employees in the commonwealth of Massachusetts. For 2026, required reporting included submitting the correct EEO-1 reports for Massachusetts locations.
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Federal & State Government EEO Reporting |
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Report |
Data Snapshot |
Deadline |
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MA State Pay Reporting |
EEO-1 snapshot of the previous year |
2/2/2026 |
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California Payroll Employee Reporting |
Any date from 10/1 - 12/31 of the previous year |
5/13/2026 |
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California Labor Contractor Reporting |
Any date from 10/1 - 12/31 of the previous year |
5/13/2026 |
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EEO-1 Reporting |
Any date from 10/1 - 12/31 of the previous year |
Anticipated Spring/Summer 2026 |
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VETS-4212 Reporting |
Any date from 7/1 - 8/31 of the current year or 12/31 of the previous year |
9/30/2026 |
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IL Equal Pay Reporting |
Depends – Bi-annual date provided by State |
Depends – Bi-annual date provided by State |
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VEVRAA Non-Discrimination Plans |
Flexible: Roster snapshot, Personnel Actions from previous year |
Plans expire 12 months after chosen plan date |
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Section 503 Non-Discrimination Plans |
Flexible: Roster snapshot, Personnel Actions from previous year |
Plans expire 12 months after chosen plan date |
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OFCCP Verification Portal* |
None currently |
None currently |

Want to take a copy to go? Download the spreadsheet with known deadlines for compliance items to share with your team.
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