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EEOC Announces it will Require both 2017 and 2018 W-2 Data By September 30, 2019 . . . But the Saga Continues

Client Alert | 1 min read | 05.06.19

The government took two significant steps on Friday regarding the battle over the EEO-1 pay data. Most notably, in response to Judge Tanya Chutkan’s recent ruling, the EEOC issued a Rule requiring employers with 100 or more employees and federal contractors with 50 or more employees to file “Component 2” W-2 earnings data for calendar year 2017 by September 30, 2019. This requirement is in addition to the mandate that such employers submit “Component 2” W-2 data for calendar year 2018 by that same date. The EEOC stated that it believes its portal will be open to receive such filings by mid-July 2019. On the same day, the Department of Justice filed a notice of appeal of Judge Chutkan’s ruling, so the fight over the EEO-1 pay data requirements will continue. However, the appeal does not stay Judge Chutkan’s ruling, so employers should prepare to file both 2017 and 2018 data by September 30th and should stay tuned, as this saga continues.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....

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