How to submit EEA2 and EEA4: the route decides the date

Which employment equity deadline binds you depends on how you file. Submit EEA2 and EEA4 by hand and the cut-off is the first working day of October. File on the department's website and you have until 15 January. Same forms, same numbers, two different dates.

Most coverage gives one of them. Which one applies to you is a consequence of a choice somebody in your business makes, usually without noticing that a choice was made.

The Employment Equity Regulations, 2025, gazetted on 15 April 2025 in Government Gazette 52515, keep both channels open. The reporting season opens on 1 September. A report may then be delivered by hand no later than the first working day of October, or filed electronically on the department's own system no later than 15 January. The Department of Employment and Labour's 2026 reporting period statement confirms 2026 as the first assessment year for all designated employers. It publishes no dates of its own.

In 2026 the first working day of October is Thursday 1 October. That puts the season opening at 1 September 2026, the manual close at 1 October 2026 and the online close at 15 January 2027. The department's own notice for the season gives the same two closing dates, and Cofesa reads the season the same way.

This applies to you if you are a designated employer. Since 1 January 2025 that means an employer of 50 or more people, an organ of state, or an employer bound by a collective agreement that says so. The turnover test that used to catch smaller employers was deleted.

The two dates are not two chances

January is not an extension of October. It is a different route with its own failure modes, and taking it is a commitment made in September whether or not anybody says so out loud.

Choosing the online route means committing to three things holding in December. Your registration on the department's system has to be live. Somebody still employed has to hold the credentials. The file your payroll produces has to be one the system accepts.

None of those get tested in October. They get tested in January, by which time the paper route closed three and a half months ago and there is nothing to fall back to.

Which route to submit EEA2 and EEA4 on, decided in September

Three questions settle it, and all three are answerable this week.

• Is the online registration live, and who holds the login? In most businesses this was set up once by a person who has since left. A password reset that needs a letter on a letterhead is a two-week job, not a five-minute one.
• Can your payroll export what the system takes, or only a spreadsheet? A spreadsheet a person retypes into a portal is a manual submission wearing a different name, and it fails at the retyping.
• Who signs, and are they in the country in December? The report carries a responsible signature. December and the first week of January are when the people who hold the answers are on leave and the people covering for them cannot approve anything.

If any of the three is uncertain, the October route is the safer one, and it has to be decided now, with less than two weeks of it left.

What the manual route asks that the portal does not

A portal validates as you type. It refuses a blank field and it will not let a total disagree with the rows above it. A paper file does none of that, so the checking has to happen before the file leaves the building.

That means the reconciliation between the workforce profile and the payroll extract has to be finished, not started, by the time you print. The two forms count the same people on two different bases, and a portal catches the mismatch for you while a courier does not.

The trade is straightforward. The October route costs you the checking effort up front and gives you certainty. The January route defers the effort and buys you a longer runway, at the price of finding out in the worst possible week whether the runway exists.

The season is entirely predictable, which is the useful part

South African employment equity reporting asks the same questions in the same months every year. That makes it the cheapest kind of work to systematise and the most expensive to keep doing from memory.

A business that captures occupational level when a person is hired, holds the plan where the plan lives, and can cut payroll on a period that is not its financial year has no route problem. It can file in October because the file is ready in September. The businesses stuck on the January date are almost never the ones with a policy gap. They are the ones assembling the numbers by hand from four systems that were never joined.

Joining a payroll system, an HR file and a reporting output so one record feeds all of them is ordinary integration work. It is the kind of single-workflow project a Zorah discovery audit tends to find first in a people function.

What to do on Monday

Open the department's online reporting system and try to log in. Do not prepare anything first. The only question is whether the credentials work today.

If they do, note who holds them and put the online route in the diary for early December, not January. If they do not, you are on the October route, and you have until the first working day of October to have the workforce records finished rather than started.

Either way, pull your workforce profile and your payroll extract into the same place this week, because the two have to agree before anybody types them. Businesses in private security should do that first, since sectoral wage grades and occupational levels are different classifications and get confused every season.