Illinois Pay Data Reporting: What You Need to Know

Illinois pay reporting requirements under the Illinois Equal Pay Act of 2003 required require certain employers to submit detailed workforce and compensation data to the state to obtain a required Equal Pay Registration Certificate (EPRC).

Initial certifications were due in 2024 and are required every 2 years. Many companies will begin entering their first two-year renewal cycle in 2026 and now is the time to review your data and reporting obligations as things have changed.

Top Takeaways for HR

• Recertification every two years is mandatory. If you filed your initial EPRC in 2024, you must proactively prepare for your two-year renewal or risk a $10,000 fine per violation.
• The state now mandates reporting on hourly vs. salaried status, base hourly rates, and collective bargaining coverage for all Illinois-based employees.
• By signing the required certification, a corporate officer is legally confirming that the company actively identifies and corrects pay disparities before the data is submitted.

What Is the Illinois Equal Pay Act

As a review, the Illinois Equal Pay Act of 2003 is designed to make sure that employees who are doing the same or substantially similar work are paid fairly, regardless of gender, race, or ethnicity. It applies to all Illinois employers, but the latest amendments place specific obligations on private sector employers with 100 or more Illinois employees.

Which Employers Must File an Illinois Equal Pay Registration Certificate

Private employers must obtain an Equal Pay Registration Certificate (EPRC) if they:

• Have 100 or more employees in Illinois, and
• Are required to file an annual EEO-1 report with the federal Equal Employment Opportunity Commission (EEOC)
• Include various business entities such as corporations, LLCs, partnerships, and trusts

Employees counted toward this threshold include:

• Workers at an Illinois office, facility, or site
• Remote employees who report directly to Illinois management

Public employers, such as government agencies or school districts, are generally exempt.

Even if you haven’t been contacted by the Illinois Department of Labor (IDOL), you’re still obligated to comply. To ensure IDOL has your correct contact information, visit the Survey of Business Contacts to submit your details.

Newly created businesses in Illinois must apply for certification within three years of becoming eligible. Refer to the Illinois EPRC FAQs for more specific information regarding filing for new and growing businesses.

HR Pro Tip: Even if your company did not initially meet the threshold, it’s worth reassessing now. Workforce growth, remote hiring, and acquisitions have pushed many organizations over the 100-employee mark since the law was first implemented.

What Data Must Employers Submit?

Illinois pay reporting requires employers to submit employee level compensation and demographic data, along with an official certification confirming compliance with equal pay laws.

The submission includes the following  three main components.

1. Employee-Level Compensation and Demographic Data

Employers must provide a dataset covering employees who worked during the prior calendar year. Required fields include:

• Employee name
• Job title
• EEO job category
• Gender
• Race/ethnicity
• Start date
• Total wages paid during the prior calendar year
• Total hours worked (check out requested data elements form to be sure this captures them all)

New Data Fields Added in Recent Updates

Beginning with the updated reporting template used for 2025 and beyond, employers must also include:

• Hourly vs. salaried status
• Hourly wage rate (if applicable)
• Whether the employee is covered by a collective bargaining agreement (CBA)

These additional fields allow regulators to conduct more detailed pay equity reviews across industries and job classifications.

Data Formatting Matters

Illinois requires employers to submit their data using the latest reporting template. Files submitted using outdated formats or altered column structures may be rejected by the system.

To avoid delays, HR teams should always download the current template directly from the reporting portal before preparing their submission.

2. Equal Pay Compliance Statement

Employers must also submit a signed statement certifying that the company complies with state and federal equal pay laws.

The statement confirms that the employer:

• Evaluates compensation practices to identify disparities
• Corrects pay differences when necessary
• Maintains nondiscriminatory pay practices across the workforce

This statement must be signed by a corporate officer, legal counsel, or authorized representative of the organization.

3. Business and Contact Information

Finally, employers must provide basic company information, including:

• Federal Employer Identification Number (FEIN)
• Corporate structure
• Illinois business locations
• Contact information for the person responsible for compliance

How Employers Submit Illinois Pay Data Reports

Employers must submit all materials through the Illinois Department of Labor Equal Pay Registration Portal.

Typical filing steps include:

1. Create or access your account on the IDOL website.
2. Upload your employee compensation data using the official template
3. Complete the compliance certification form
4. Pay the filing fee (currently $150)
5. Submit the application for review

The portal now includes fillable forms and electronic signature options, making the submission process more streamlined than in earlier filing cycles.

Illinois Pay Reporting Deadlines and Recertification

Understanding the timing requirements is critical for maintaining compliance. Here are the key deadlines to keep on your radar:

Initial Certification

The first major filing wave occurred in 2024, when many employers submitted their initial Equal Pay Registration Certificate applications.

Recertification Requirement

Employers must renew their EPRC every two years.

Example timeline:

• Initial certification: 2024
• First renewal: 2026
• Next renewal: 2028

Because of this cycle, many employers that filed in 2024 will need to begin preparing their first recertification submission in 2026.

Rolling Filing Windows

The Illinois Department of Labor assigns individual filing windows and notifies employers directly.

Once notified, employers generally have 120 days to submit their report.

If the filing window is missed, the state may issue a Notice of Delinquency, giving employers 30 days to correct the issue before penalties are applied.

HR IRL: An HR leader at a mid-sized technology company completed their first Illinois pay report in 2024.

When preparing for recertification, they discovered several challenges:

• Rapid hiring had pushed their Illinois workforce well beyond the reporting threshold
• Several roles had been placed in incorrect EEO job categories
• Their HRIS system didn’t consistently track hourly vs. salary status

The HR team ultimately had to rebuild their dataset just weeks before their deadline.

Situations like this are common and they highlight why many companies conduct internal pay data reviews well before their reporting window opens.

“Illinois is clearly moving toward deeper pay transparency and stronger enforcement. Employers shouldn’t treat the Equal Pay Registration Certificate as a simple reporting exercise. The data being submitted is increasingly detailed, and organizations that prepare their pay data early, and analyze it before filing, will be in a much stronger compliance position.” —Neil Dickinson, VP Compensation Services at OutSolve.

Penalties for Non-Compliance

Failing to comply with Illinois pay reporting requirements can lead to significant penalties.

Employers may face:

• Civil penalties of up to $10,000 per violation
• Additional fines for ongoing violations
• Suspension or revocation of the Equal Pay Registration Certificate

If a certificate is revoked, the employer may face challenges with contracts, funding opportunities, or other business operations within the state.

Tips for Staying Compliant with Illinois Pay Reporting

Managing pay reporting effectively requires ongoing preparation. HR teams that approach reporting proactively tend to experience fewer filing issues.

Here are several best practices:

• Prepare Data in Advance: Start collecting and reviewing compensation data well before your filing window opens.
• Use the Latest Reporting Template: Illinois periodically updates reporting formats, so always verify you are using the current version.
• Audit EEO Job Classifications: Confirm that employees are placed in the correct EEO categories, particularly for hybrid or emerging job roles.
• Conduct a Compensation Analysis: Running a pay equity analysis before submitting your report can help identify potential disparities and allow time to address them internally.
• Monitor Your Workforce Size: Companies that previously fell below the reporting threshold may now qualify due to hiring growth or structural changes.
• Monitor Deadlines: Mark certification and recertification dates on your calendar to stay ahead of deadlines. 
• Consider Expert Support: Many companies now rely on an HR Compliance as a Service (HR CaaS) model to manage complex reporting requirements, especially when operating in multiple states with evolving pay transparency laws.

Common Illinois EPRC Filing Mistakes (and How to Avoid Them)

Even experienced HR teams run into challenges when preparing their Equal Pay Registration Certificate submissions.

Here are several common mistakes and how to avoid them.

• Using an Outdated Reporting Template: Illinois periodically updates its reporting template, and submissions using older formats may be rejected.
  
  

  How to avoid it: Download the latest template from the reporting portal each time you prepare a new submission.

• Incorrect EEO Job Categories: Misclassifying employees into the wrong EEO job category is a frequent error.
  
  

  How to avoid it: Review official EEO category definitions and confirm that job roles align with those classifications.

• Incomplete Compensation Data: Missing new reporting fields, such as hourly status or hourly wage, can delay submissions.
  
  

  How to avoid it: Validate your dataset before uploading and confirm that your HRIS captures all required fields.

• Waiting Until the Filing Window Opens: Some companies delay preparation until they receive their filing notice.
  
  

  How to avoid it: Start preparing data several months in advance to allow time for corrections.

• Not Monitoring Workforce Growth: Employers sometimes assume they don’t need to file because they didn’t meet the threshold previously.
  
  

  How to avoid it: Regularly review employee headcount in Illinois to determine whether reporting requirements now apply.

What Illinois Pay Data Reporting Means for Your Organization

Illinois pay reporting is part of a broader shift toward pay transparency and workplace equity.

To stay compliant, employers should:

• Confirm whether they meet the 100-employee Illinois threshold
• Maintain accurate employee pay and demographic data
• Track recertification deadlines every two years
• Conduct internal compensation reviews before submitting reports

For many companies, managing changing pay reporting requirements can become complex, especially when multiple states have their own regulations.

That’s why many HR teams partner with HR compliance as a service (HR CaaS) experts like OutSolve to manage pay reporting, compensation analysis, and multi-state compliance strategies. With the right systems and support in place, Illinois pay reporting can become a structured, manageable part of your companies overall compliance program.

Illinois Pay Data Report FAQs

1. Who must file an Illinois Equal Pay Registration Certificate?

   Private employers with 100 or more employees in Illinois are required to obtain an EPRC.

2. How often must the Equal Pay Registration Certificate be renewed?  

   Employers must recertify every two years after receiving their initial certification.  

3. What new information must be included in Illinois pay reporting?

   Recent updates require employers to report:

   • Hourly vs. salaried status

   • Hourly wage rate (if applicable)

   • Whether employees are covered by a collective bargaining agreement

4. What happens if an employer misses their filing deadline?  

   The Illinois Department of Labor may issue a Notice of Delinquency, giving the employer 30 days to correct the issue before penalties are imposed.  

5. What penalties apply for failing to comply with Illinois pay reporting laws?  

   Employers may face civil penalties up to $10,000 per violation, along with potential suspension or revocation of their Equal Pay Registration Certificate.  

Need help? Many HR professionals are turning to advisory firms, such as OutSolve, to simplify Illinois pay data reporting. Whether you're filing for the first time or gearing up for a renewal, it's okay to get a little help. Compliance doesn't have to be complicated. If you have any questions or need further assistance, feel free to reach out. We're here to help you navigate this process smoothly!