Last month, on the seventh anniversary of the Lilly Ledbetter Fair Pay Act, the EEOC introduced a proposal to expand the information collected from federal contractors and employers with more than 100 workers on annual EEO-1 filings. In addition to race, gender and ethnicity information, which is already required,  the proposal requires employers to include compensation information. This includes data on pay ranges and hours worked beginning with the September 2017 report. The proposal did not address the many lawful variables that can account for pay differentials such as seniority, education, and performance. Employers should be proactive and conduct a privileged analysis of their pay practices to assess compliance and any apparent disparities. Comments on the EEOC’s proposed rule will be accepted through April 1, 2016.