Mastering EEO Categories

While there have been many changes in the EEO/Non-Discrimination world in the past year, correctly identifying and categorizing your jobs into EEO-1 categories remains important.

Compliance filings such as the EEO-1 report, Vets-4212 report, California Pay Filing, and other state filings utilize EEO-1 categories, and those filings should use accurate workforce data. In addition, there are still affirmative action program requirements under VEVRAA and Section 503 of the Rehabilitation Act that rely on accurate job groups within those reports.

EEOC Filings

Most employers are familiar with EEO-1 reporting. For anyone unfamiliar (or those who could use a refresher), the EEO-1 Component 1 report is a mandatory annual data collection that requires private sector employers with 100 or more employees, and federal contractors with 50 or more employees meeting certain criteria, to submit workforce demographic data to the EEOC (Equal Employment Opportunity Commission). The EEOC has been collecting EEO-1 report data since 1966 with the purpose of using that data to support civil rights enforcement. The 2024 EEO-1 filing, using 2024 data and filed in 2025, has closed. The 2025 filing deadline has not yet been announced.

Organizations other than private employers may also be subject to similar EEO workforce data reporting requirements under federal law:

• The EEO-3 Data Collection (Local Union Report)
  • Biennial data collection conducted every other year in the even-numbered calendar years from Local Referral Unions.
• The EEO-4 Data Collection (State and Local Government Information Report)
  • A mandatory biennial data collection that requires all state and local governments with 100 or more employees to submit workforce demographic data to the EEOC.  
• The EEO-5 Data Collection (Elementary - Secondary Staff Information Report)
  • A mandatory biennial data collection that requires all public elementary and secondary school systems and districts with 100 or more employees to submit demographic workforce data.

EEO-1 Job Categories

For EEOC workforce data reporting, employers are required to group their jobs into various categories developed by the EEOC. For the EEO-1 report, the EEOC uses a list of 10 job categories. Various other official workforce data reporting, including state and local reporting, utilizes these same 10 EEO-1 job categories.

• 1.1 – Executive/Senior Level Officials and Managers
• 1.2 – First/Mid-Level Officials and Managers
• 2 – Professionals
• 3 – Technicians
• 4 – Sale Workers
• 5 – Administrative Support Workers
• 6 – Craft Workers
• 7 – Operatives
• 8 – Laborers and Helpers
• 9 – Service Workers

Why does the EEO-1 use specific job categories?

Bucketing groups of like-jobs into distinct categories helps the EEOC uniformly evaluate workforce data across different employers and industries. Having defined categories allows for clearer analysis of differences between the job categories, and thus clearer identification of potential industries, job types, and/or geographic areas where women and minorities might be underrepresented in certain roles.

“Affirmative Action” and Non-Discrimination Plans

Until the revocation of Executive Order 11246, EEO-1 job categories formed the basis of job groups structures for Affirmative Action Plans for women and minorities. Section 60-2.12 of the federal regulations required contractors to combine job titles into groups of similar content, wage rates and opportunities, thus allowing meaningful analysis of similarly situated jobs. Contactors with fewer than 150 employees were permitted to use the EEO-1 categories as their job groups. Employers with 150 employees or more employees were required to further sub-divide the EEO-1 categories into smaller job groups of similar jobs.

While federal contractors are no longer required to create race and gender based plans under EO 11246, contractors still need to create plans for Protected Veterans and Individuals with Disabilities, which still require analysis by job group, Absent any further guidance on how to group employees for Protected Veteran and Individuals with Disabilities plans, the principles remain the same for grouping jobs into job groups, starting with the EEO-1 structure to create well defined job groups that are still important for analysis.

Other Compliance Reports

The Vets-4212 reports require federal contractors to submit aggregate establishment-based data of Protected Veteran categories for employees and new hires at the EEO-1 category level. There are also countless State and local reports that require EEO category data too. For example, the CA Pay filing requires detailed pay data across many strata, including EEO-1 category, although California will move towards reporting by 23 related, but more granular, standard occupational classification major groups next year. The Massachusetts pay filing currently requires EEO-1 reports to be submitted and Illinois requires reporting by the same ten job categories.

EEO-1 Job Categories in Detail

Even with the revocation of EO 11246, it is still important for companies to maintain accurate data in their HRIS (Human Resources Information System) and ATS (Applicant Tracking System) for compliance reporting and workforce analysis. When new jobs occur, the roles and responsibilities of those jobs should be considered to ensure correct and accurate categorization of those jobs within systems of record. Existing jobs should be reviewed periodically to ensure that they too are accurately recorded as their roles and responsibilities may shift, requiring a change of category.

Below are details and example roles for each of the EEO-1 job categories. Berkshire has developed a quick reference guide to the EEO-1 job categories. (as well as the EEO-4 job categories and EEO-6 job categories).

These are the highest-level job titles in an organization. Executive/Senior Level Officials and Managers create and manage overall company policies, define company strategies, and provide overall direction for an organization, with the support of subordinate executives and managers, and within the parameters approved by boards of directors or other governing bodies.

The Executive/Senior Level Officials and Managers category can also include, in larger organizations, those that are within two reporting levels of the CEO, and whose responsibilities involve frequent interaction with the CEO.

Examples: chief executive officers, chief financial officers, chief information officers, chief human resources officers, chief legal officers, line of business heads, presidents, executive vice presidents, management directors, and managing partners.

These are managers other than those at the executive level, who often report to executive-level officials. Jobs in the First/Mid-Level Officials and Managers category may be responsible for implementing the plans and strategies set by executive-level officials. They may also oversee and direct the delivery of products, services, or functions at group, regional, or divisional levels of organizations.

Jobs in this category are often people managers, but not always – and they do not always report to executive-level management. This category can also include jobs that report directly to middle-management but are responsible for overseeing day-to-day operational objectives for a branch or area of a company.

Examples: vice presidents, directors, group, regional or divisional controllers, treasurers, human resources, information systems, marketing, operational managers, first line managers, branch managers, and storage and distribution managers.

These jobs require a bachelor’s or graduate degree, professional certification, or comparable experience. Jobs in the Professionals category do not typically manage others, although their roles may be Team Leads.

Examples: accountants and auditors, airplane pilots and flight engineers, computer programmers, chemists, lawyers, librarians, physician scientists, physicians, teachers, and engineers.

Jobs in this category require applied scientific skills, which are usually obtained through post-secondary education of varying lengths, depending on the particular occupation. These jobs often involve repetitive technical/manual work requiring re-certification.

Examples: drafters, emergency medical technicians, chemical technicians, HVAC maintenance technicians, lab technicians, and pharmacy technicians.

These jobs are non-managerial jobs that primarily involve direct sales. For sales jobs with multiple responsibilities, they must spend more of the time selling than completing the other tasks (for example, a sales manager role must spend more time actively selling than managing a sales team.)

Examples: retail workers, loan officers, insurance agents, wholesale sales representatives, counter and rental clerks, and cashiers.

These are jobs involving non-managerial tasks that provide administrative and support assistance, typically in an office setting. Jobs in this category may have a two- or four-year college degree, high school diploma, or equivalent.

Examples: administrative assistants, receptionists, paralegals, accounts payable/receivable support staff, shipping, receiving, and traffic clerks, proofreaders, and data entry keyers.

Most jobs in this category include higher skilled occupations in construction, natural resource extraction, or equipment installation, maintenance and repair. Some production occupations will be included in this category, distinguished by the high degree of skill and precision required to perform the job, based on clearly defined task specifications.

Jobs in this category often involve specific vocational or apprenticeship training in a skilled trade or professional craft, often requiring unique tools, creativity, and attention to detail.

Examples: carpenters, stone masons, plumbers, electricians, painters, roofers, welders, auto mechanics, boilermakers, pipe layers, elevator installers, tailors, millwrights, etchers and engravers, and pattern makers.

Most jobs in this category include intermediate-skilled occupations and include workers who operate machines or perform other factory-type duties, including but not limited to operating and controlling equipment to facilitate the movement of people or materials.

Jobs in this category require less training than a Craft Worker, but are still semi-skilled, usually requiring not more than a few months of training to become proficient. They are often trained in-house by the employer.

Examples: forklift drivers, bus drivers, truck drivers, flight attendants, printing press operators, sailors, parking lot attendants, and hand packers and packagers.

Jobs in this category typically include workers with more limited skills who require only brief training to perform tasks that require little or no independent judgment. They typically follow instructions and perform manual labor.

Examples: production and construction worker helpers, vehicle and equipment cleaners, laborers, freight movers, groundskeepers, refuse and recyclable materials collectors, and sewer pipe cleaners.

This category includes workers in both protective and nonprotective service occupations, that provide a personal service to the public. Skills for these jobs may be acquired through formal training, job training, job-related training, or direct experience. They may also have state licensing.

Examples: bartenders, waiters, chefs, janitors, lifeguards, police, firefighters, home health aides, private detectives and investigators, and medical assistants or other healthcare support positions.

Hopefully, the above list of EEO-1 categories will help you and your organization develop and maintain accurate workforce data to assist in effective workforce analytics and accurate and timely compliance filings.

Key Takeaways:

• Accurate EEO-1 coding remains important as scrutiny increases on workforce analytics and compliance filings

• Assign appropriate EEO-1 categories to new jobs as they occur

• Review all jobs, or at least those with changed responsibilities, for EEO-1 category accuracy on an annual basis

• Be proactive in your review – it’s too late to review lots of jobs right before a compliance filing deadline

• Ask for help if you are not comfortable with the review – we can help you!