As 2025 progresses, employers face several notable compliance updates from the U.S. Equal Employment Opportunity Commission (EEOC) and U.S. Citizenship and Immigration Services (USCIS). These changes involve key workforce reporting requirements and hiring documentation processes; staying compliant in 2025 with these changes is essential for businesses that want to avoid potential legal or operational missteps.
At Rudman Winchell, our Employment Law team is committed to helping Maine businesses and organizations understand and adapt to evolving federal regulations. Below, we’ve broken down what you need to know, what’s changing, and how to prepare.
EEO-1 Reporting Requirements: 2025 Deadlines and Gender Category Changes
Who Must File:
The EEO-1 Component 1 report is required for private-sector employers with 100 or more U.S.-based employees. Certain federal contractors with at least 50 employees may also be subject to filing, though that requirement is under review (more on that below).
Key Dates:
- Reporting Portal Opens: May 20, 2025
- Deadline to File: June 24, 2025
What’s Reported:
Employers must classify and report their workforce by race, ethnicity, gender, and job category. This data is used by the EEOC to enforce federal anti-discrimination laws and monitor employer compliance.
Proposed Change to Gender Classification:
A significant proposed revision for 2025 involves the removal of the non-binary gender option that was introduced in the 2023 guidance. If adopted, employers would only be permitted to classify employees as male or female, aligning with Executive Order 14168:
“Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.”
This revision could require updates to your HR information systems and internal employee data collection procedures. While many employers voluntarily reported non-binary data in previous years using a comment field, that flexibility may no longer be available.
Status of Federal Contractor Filing:
Federal contractors with 50 or more employees were historically required to submit EEO-1 reports under Executive Order 11246. That order has now been revoked, raising uncertainty about whether the reporting requirement still applies to those employers. Notably, the EEOC’s current instruction booklet still references the requirement, but updated guidance is expected before the portal opens.
✅ Tip for Employers: If you’re unsure whether your organization still qualifies as a covered federal contractor for EEO-1 purposes, it’s wise to consult legal counsel. Erring on the side of caution and preparing to file may help you avoid last-minute scrambling.
Form I-9 Updates: What You Need to Know About the New Version
Employers are also facing changes to the Form I-9, which is used to verify the identity and employment authorization of individuals hired for employment in the United States.
New Form Released:
The latest version of Form I-9 is dated January 20, 2025. While prior versions (such as the 2023 form) remain valid until their expiration dates, employers should be aware of several updates:
- Revised Language in Section 1: The fourth checkbox in Section 1 has been updated to state “An alien authorized to work.” This change reflects new statutory language adopted by the federal government.
- Electronic System Deadline: Employers who utilize electronic onboarding systems must ensure those platforms are updated to incorporate the 2025 form no later than July 31, 2026.
E-Verify System Changes:
As of April 3, 2025, the E-Verify and E-Verify+ systems have been updated to reflect the new wording. When creating a case, the selection previously labeled “A noncitizen authorized to work” will now appear as “An alien authorized to work.”
✅ Tip for Employers: It’s a good idea to begin reviewing your I-9 procedures now, particularly if you use an electronic system or work with third-party vendors. Verifying that your onboarding process matches the new federal language helps ensure seamless compliance.
Next Steps for Employers
Between workforce demographic reporting and employee authorization verification, there’s a lot to manage with staying compliant in 2025. To stay ahead of these evolving requirements:
- Audit Your Workforce Data: Ensure your HR systems align with EEO-1 reporting requirements—especially if the proposed gender classification change is finalized.
- Review Onboarding Processes: Update your Form I-9 documentation and confirm that your HR and compliance staff are trained on the new form language.
- Clarify Contractor Status: If you’re a federal contractor or subcontractor, stay alert for additional guidance from the EEOC about your EEO-1 obligations.
- Plan Ahead: Don’t wait until deadlines approach. Early planning can help avoid costly errors or delays.
Staying Compliant in 2025: Rudman Winchell Can Help
Navigating federal employment compliance can be complex—especially when rules and forms are changing. At Rudman Winchell, we provide trusted legal guidance to employers across Maine, helping them build strong, compliant workplaces. If you have questions about these updates or need assistance with filing, onboarding, or compliance audits, we’re here to help. Contact us today to schedule a consultation with our Employment Law team.
