Effective July 1, 2027, certain employers in Colorado will be required to provide EEO-1 data to the Colorado Secretary of State, even if the federal government repeals or discontinues the requirement to submit EEO-1 data to the Equal Employment Opportunity Commission (EEOC). Under the Colorado law, EEO-1 data means demographic workforce data collected through the EEO-1, as that form existed on March 1, 2026. The data categorizes employees by race, gender (sex), and job categories.
An employer is defined as a private sector entity conducting business in Colorado that employs 100 or more workers and is required to submit EEO-1 data to the EEOC (as of March 1, 2026). An employer does not include the state, local governments, the federal government, school districts, state colleges or universities, or any quasi-governmental entity or political subdivision.
At the federal level, the EEOC issued a notice of proposed rulemaking (NPRM) in July to stop filing requirements for the EEO-1, as well as its related recordkeeping and record preservation requirements for most employers.
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Lia Coniglio, Esq., is Managing Editor of PayState Update and Senior Manager of State Payroll Information Resources for PayrollOrg.