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Is there a requirement for the Catholic Church to file an EEO-1 Report?

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Legally, there is no “Catholic Church”

The Catholic Church in the USA is a hodge-pudge of legal structures (predominantly trusts, corporations sole, and regular corporations) governed by disparate state law. In most cases, each conceptually distinct part of the church - parishes, bishoprics, schools, seminaries, cemeteries, universities, holy orders etc. - is its own legal entity.

Whether each part needs to respond to EEO-1 reporting depends on if it individually meets the 100 employee threshold. The overwhelming majority won’t meet the threshold. Those that do, need to file a report subject to the religious category exemption.

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    While your point is well taken, most Roman Catholic Church entities in the U.S. would have more than 100 employees. At the level of church operations, all of the parishes and administrative staff (including canon law courts) are usually under a single corporation sole of a bishop or archbishop in the U.S., Catholic schools, colleges, universities, and hospitals tend to have lots of employees each. Cemeteries are usually part of the same entity as the parishes under a bishop. Holy orders often have a global entity that due to their large geographic research is over 100 employees.
    – ohwilleke
    Apr 11, 2023 at 1:06
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29 CFR Part 1602 says (§1602.7)

every employer that is subject to title VII of the Civil Rights Act of 1964, as amended, and that has 100 or more employees shall file with the Commission or its delegate executed copies of Standard Form 100

which is "EE0-1". The Catholic Church is not fully exempt. The requirement does not apply

to a religious corporation, association, educational institution, or society with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities.

There is no exemption for reporting as regards race, color, gender, pregnancy, or national origin.

Picking one state as an example (Washington), there are three corporations corresponding to the diocese of Seattle, Yakima and Spokane. It is hard to interpolate from known resources to employees, but there are almost 200 Catholic churches in the Seattle diocese, and 75 schools, so it is likely that this diocese passes the 100 employee threshold.

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