EEA2 and EEA4 ask two systems for the same people

To submit an employment equity report for 2026 you have to produce two returns that agree with each other. The EEA2 workforce profile comes out of your HR records. The EEA4 income differential statement comes out of payroll. Both are cut on a period ending 31 August, which is almost certainly not your financial year.

That last point is where most of the work hides, and it is the one nobody writes about. Every South African title publishes the deadline. The reconciliation behind it gets published nowhere.

The period is fixed, and it is not your year

The 2026 reporting period is standardised to 1 September 2025 through 31 August 2026. It does not flex to suit your accounts.

BEE123's write-up of the Department's 2026 roadshows puts the consequence plainly. Employers need to ensure their HR and payroll systems can produce accurate information for the prescribed reporting period, rather than relying on their own financial-year data.

Read that against how a 40-person business is actually run. Your payroll reporting is built around your own financial year end, whatever it is, because that is what the auditors ask for and what the annual tax reconciliation needs.

Nobody has ever asked payroll for a twelve-month cut running September to August. The report exists, in the sense that the data is there. It has never been run, and the first person to run it will find out on a Tuesday in October whether it balances.

Eight things to verify, sitting in four systems

The roadshows set out an internal verification process to run before final submission. The list is worth reading as a systems inventory rather than a compliance checklist:

• Total workforce reconciliation
• Occupational level classifications
• Race and gender information
• Disability information
• Consistency between the relevant EEA2 tables
• Annual targets
• EEA4 income differential information
• The reporting period

Now place each one. Headcount is in payroll, and probably also in a spreadsheet that disagrees with payroll by three people. Occupational levels sit in a file somebody built for a previous return. Race, gender and disability come from a recruitment folder, and only for people hired since it was set up. Income sits in payroll and is the only item on the list nobody argues about.

Annual targets sit in the plan document. The reporting period sits in nobody's system at all, which is the entire problem.

Four sources, eight checks, and the two returns have to tell the same story about the same people.

Where the two returns come apart

The join between EEA2 and EEA4 is the occupational level. The workforce profile reports who sits at each level. The income differential statement reports what is paid at each level.

A person who was promoted in March sat at one level for six months of the reporting period and another level for the rest of it. Your HR record may show only the current level, because it was overwritten. Your payroll shows the pay change, because payroll cannot overwrite history without breaking a payslip.

That is the shape of the discrepancy, and it does not announce itself. Both numbers look right on their own. They stop looking right the moment somebody reads them side by side, which happens either during your own verification or during somebody else's.

Terminations do the same thing in reverse. A resignation processed late in payroll and immediately in the HR system produces two different headcounts for the same month.

Submit is not a draft

The roadshows carried one warning that changes how much of this matters. Employers should carefully verify their reports before final submission, and should not assume that inaccurate information can simply be corrected afterwards.

That is a different risk profile from the one most people are working to. A return you can fix later is a first draft. A return you cannot fix later is the record, and in 2026 the data in it also decides whether the system marks each of your annual numerical targets achieved, exceeded or not achieved.

An error in an occupational level classification is no longer an administrative slip. It moves a person between two rows, and the rows are what get assessed.

Three dates and where they land

The dates below were checked on 24 August 2026 and should be checked again before you rely on them. Reporting opens on 1 September 2026. Manual submissions close on 1 October 2026. The online system runs to 15 January 2027.

Those three dates are carried by Cofesa and by ClearComply, which agree on all of them. The Department's own media statement of 4 August 2026 announces the period without publishing the dates, so confirm them on the reporting system itself when it opens.

The gap between the two closing dates is the useful part. Manual gives you a month. Online gives you four and a half, and the reason to use the extra time is not procrastination. It is that a reconciliation between two systems takes longer than a form does, and the form is the last step rather than the first.

Joining a payroll and an HR record so that occupational level, effective dates and pay live against the same employee, with history preserved, is ordinary integration work. It is the kind of thing a Zorah discovery audit tends to find first, because the same join fixes the B-BBEE return and the skills development report at the same time. It is a workforce problem that only looks like a compliance problem once a year.

What to do this week

Ask payroll for one thing: a list of every employee who changed occupational level between 1 September 2025 and 31 August 2026, with the effective date of each change.

If that report comes back in an hour, your two returns will reconcile and the rest of the submission is data entry. If it comes back as a question, you have found the gap with time left rather than in October.

Then run the same request against your HR system and compare the two lists. The people who appear on one and not the other are the ones your submission will disagree with itself about.