Illinois Employers Get Ready—Busy Equal Pay Reporting Season Is Coming

Quick Hits

• In 2021, Illinois amended its Equal Pay Act of 2003, requiring covered employers to submit demographic and wage data to the Illinois Department of Labor (IDOL) to obtain an Equal Pay Registration Certificate (EPRC).
• Employers that have one hundred or more Illinois employees must obtain an EPRC.
• An employer’s EPRC must be renewed every two years.
• Employers must count employees physically working in Illinois, as well as fully remote employees who report to management in Illinois, to determine if they must file the EPRC application.
• For the 2025 submission cycle, the IDOL has made a few changes to the data template and submission process.

EPRC Renewals

In early 2025, the IDOL presented webinars discussing the history of EPRC filings, the changes for the 2025 EPRC renewals, and the highlights of its increased enforcement efforts. This information suggests that more than 70 percent of EPRC renewals will be due in late 2025 and in the spring of 2026. As employers begin to prepare for these renewals, here are several factors to consider:

• All 2025 renewals will be based on data from calendar year 2024, which means that the submission work can begin now even if the renewal deadline is later in 2025.
• There are new requirements for 2025 filings, which will require additional data and work on the employer side compared to the initial filing cycle.
• In late 2023, when many employers filed their initial EPRC applications, there were many filing site disruptions. While these were eventually resolved and the filing platform was updated in the spring of 2025, it seems possible that there could be filing platform issues again in late 2025.

Based on these factors, employers that have a renewal due in 2025 may want to prepare a plan for their EPRC renewal now to avoid issues later in the renewal process.

New EPRC Filers

Employers with Illinois employees that have not previously obtained an EPRC certificate can look to the IDOL’s frequently asked questions (FAQs) guidance on the EPRC to determine if they are required to file a first-time EPRC application in 2025.

Updates for 2025

All employers that are filing their EPRC materials may want to note that the data template has been updated to include information about whether an employee is paid on an hourly or salaried basis and whether an employee is covered by a collective bargaining agreement. The required compliance statement is also now included in the employer portal and does not need to be uploaded as a separate document.

Ogletree Deakins’ Chicago office, Government Contracting and Reporting Practice Group, and Pay Equity Practice Group will continue to monitor developments with respect to the Illinois EPRC application process and will provide updates on the firm’s Government Contracting and Reporting, Illinois, and Pay Equity blogs as additional information becomes available.

On Friday, August 15, 2025, from 1:00 p.m. to 2:00 p.m. CDT, James A. Patton, Jr. and Kristi Nelson Foy will present a webinar, “Preparing for the 2025 Illinois Equal Pay Registration Certificate Renewal Process.” They will cover the steps employers can take now to prepare for Illinois’s upcoming busy equal pay reporting season. Register here.

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