Filing a charge of employment discrimination with the Equal Employment Opportunity Commission (EEOC) can be confusing when determining who the employer is. That’s especially true in a complex corporate environment, where multiple companies may seem to be in charge.
This is where the “integrated enterprise doctrine” comes in. It’s a legal concept used by courts to determine whether two or more legally separate businesses should be treated as a single employer for the purposes of federal anti-discrimination laws, like Title VII of the Civil Rights Act of 1964.
What Is the Integrated Enterprise Doctrine?
Only employers with 15 or more employees are subject to the provisions of Title VII. Sometimes companies try to avoid liability by dividing their operations into smaller entities, each with fewer than 15 employees—or by claiming that the entity accused of discrimination isn’t technically the complainant’s employer.
The integrated enterprise doctrine helps prevent companies from using these structures to dodge responsibility.
Courts applying the doctrine consider four key factors:
1. Common management – Do the companies share the same managers or decision-makers?
2. Interrelation of operations – Are things like payroll, HR, or benefits shared?
3. Centralized control of labor relations – Who makes decisions about hiring, firing, discipline, or promotions?
4. Common ownership or financial control – Are the companies owned by the same parent or individuals?
No single factor is decisive. But if enough of them point toward integration, the court may treat the companies as a single employer for purposes of liability under Title VII.
Why This Matters for Discrimination Claims
A small subsidiary of a national corporation has an employee who may have been discriminated against, but the local subsidiary has only 10 employees. Normally, that would put it below the threshold for a Title VII claim.
But, if that subsidiary is part of an integrated enterprise with its parent company or other affiliates, and together they have 15 or more employees, then the employee may still have a viable Title VII claim.
Do All Employers Need to be Named in the EEOC Charge?
One of the most common questions people ask when filing with the EEOC is:
“Do I have to name every possible employer in my EEOC charge? What if I’m not sure?”
Generally, yes—all parties who may be responsible should be named. However, failing to name a party doesn’t always end a case. Courts recognize that many employees aren’t legal experts, and EEOC charges are often completed without a lawyer. So, they’ve developed what’s called the “identity of interest” exception.
Under this rule, a defendant that was not named in the EEOC charge may still be sued in court if it had a close enough relationship to the named party and had adequate notice of the charge and an opportunity to respond during the EEOC’s investigation.
In other words, if two companies are part of the same integrated enterprise, and one was named in the EEOC charge, the other might still be brought into a lawsuit—especially if it was involved in the events described and knew (or should have known) about the claim.
Final Thoughts
The integrated enterprise doctrine plays a crucial role in ensuring that the law can’t be sidestepped through corporate structuring. If an employee has experienced workplace discrimination and is unsure who their legal employer is—or whether they need to name multiple companies in their EEOC charge—it’s a good idea to seek legal advice early.
