As a reminder for Illinois employers with 100 or more employees in the state of Illinois, the Illinois Department of Labor (IDOL) has expanded its Equal Pay Registration Certificate (EPRC) requirements. All private employers meeting this threshold—regardless of whether they file a federal EEO-1 report—must obtain an EPRC and recertify it every two years.

Who Must Comply

• Private employers with 100 or more employees physically working in Illinois or remote employees who report to Illinois-based management.
  • Government entities are excluded from this requirement.

Certification Timeline

• Existing businesses: Must certify within 3 years of the law’s effective date and recertify every 2 years.

• New businesses: Must certify within 3 years of starting operations and recertify every 2 years.

What’s New in 2025

• Starting March 2025, employers must include additional data in their submissions:

• Hourly vs. salary status.
  • Base hourly rate for hourly workers.
  • Collective bargaining agreement status.

• A new data template will be available on IDOL’s EPRC page by March 31, 2025.

• IDOL may issue further guidance on complex pay scenarios, such as shift differentials.

Compliance and Enforcement

• IDOL is increasing enforcement efforts:
  • EPRC denials rose from 25 in FY 2022 to 89 in FY 2024.
  • Registrations revoked: 12 in FY 2024.
  • Notices of violation: 63 issued so far in FY 2025.

• Common issues for recertifying employers include:
  • Changes in job classifications or entity names
  • Departure of the original contact person
  • Employers should contact DOL.EPRC@illinois.gov to resolve these issues.

Important Dates

• Employers who were due to recertify in early 2025 had their deadline extended to March 31, 2025, due to portal updates.

• Employers who missed the March 31 deadline are encouraged to review their status and take appropriate steps to address any outstanding requirements.

Resources Available:

IDOL will provide:

Updated pay data templates.

• A compliance statement template
• FAQs and additional guidance
• All resources will be available on the IDOL EPRC landing page.

For additional information:

• December 2022: Reminder: Illinois Equal Pay Act Goes Into Effect In 2023 (VensureHR)
• Illinois – Equal Pay Registration Certificate (EPRC)
• Equal Pay Registration Certificate (EPRC) – FAQS

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