Labor reminds employers of COE requirements, common reporting issues
The CNMI Department of Labor reminds all employers of their responsibility to submit accurate and timely Census of Employment forms each quarter.
“As we close out a year since implementing the updated COE forms and submission process in the first quarter of Calendar Year 2024, we have observed a number of recurring issues that may delay processing or complicate compliance,” said Labor.
To ensure accurate reporting and compliance, please carefully review and take note of the following common errors and essential reminders:
1. Use the correct Census of Employment form
Many employers are still using outdated versions of the COE form. The latest version of the form is dated July 16, 2024. Reporting with the old form may result in inaccurate counts, particularly regarding separated employees and EAD-C37 visa holders. Please use the updated form available on the website, which includes drop-down menus and automatically calculates various visa statuses within the U.S. full-time and part-time employee counts. In addition, ensure that only employees who worked during the current quarter are reported. If an employee has separated, include them in the report for their final quarter of employment, but do not continue reporting them in future quarters.
2. Submit to the correct destination
All COE forms must be submitted through the official online portal at https://labor.cnmi.gov rather than via email or to individual staff members. The previous Outlook email service is no longer active, and staff members are transitioning to the new system. Submitting your COE through the DOL website ensures that it is directed to the correct processing location for prompt review and handling.
3. Complete the certification section on the COE form
Please ensure that the certification section on the COE form is fully completed. Incomplete certification can result in delayed processing and may require a resubmission.
4. Verify attachments on the online submission
Please verify that the attachment corresponds to the correct company and reporting quarter. To avoid delays, ensure the COE form is fully completed and accurate before submitting, and avoid submitting blank or incomplete forms
5. Include complete company information
The COE form must display the business name exactly as it appears on the official business license. If a DBA (Doing Business As) name is used, include it along with the licensed business name to ensure clarity and accuracy.
6. Avoid duplicate submissions
Please refrain from submitting multiple versions of the same COE form unless a revision or amendment is explicitly requested by DOL. If an amendment is required, indicate “Yes” on the amendment/revision question on the form. This helps our team quickly identify the final version of your submission.
7. Respond quickly to amendment requests
When a COE form requires correction, please resubmit promptly. Delays in resubmission result in an incomplete submission, affecting compliance and data accuracy and may lead to a referral to DOL enforcement.
Over the past year, Labor hasfound that almost 60% of submissions contain errors, underscoring the importance of thorough review and correct use of the COE form. Accurate quarterly data is crucial for compliance and aids in workforce planning, labor market analysis, and maintaining CNMI’s economic health.
For more information, visit Labor’s website at labor.cnmi.gov or contact our Administrative Services office at (670) 664-3196. Thank you for your attention to these requirements and for your continued cooperation. (PR)

CNMI Labor
