Illinois Equal Pay Registration Certificate
Illinois requires private employers with 100 or more employees in Illinois to obtain an Equal Pay Registration Certificate and recertify every two years.
It is the most data-intensive state pay filing in the country. Unlike California's aggregated pay bands, Illinois collects individual-level records for every employee.
Who has to file?
Any private employer with 100 or more employees in the State of Illinois. Government entities are excluded. Multi-location businesses file one application covering all Illinois operations.
How to count Illinois employees: individuals who worked at your Illinois facility, plus fully remote employees who report directly to Illinois management. The count is taken as of December 31 of the year preceding the deadline.
That remote rule is worth attention - an employee living in another state who reports into an Illinois manager counts toward an Illinois threshold.
The cycle
- Recertify every two years from the date your last certificate was issued
- The portal sends automated reminders at 180 days and 60 days before expiration
- The agency must approve or deny within 45 days
- If rejected, you have 30 calendar days to cure and resubmit
- Filing fee: $150 per submission
- New businesses submit contact information by January 1 of the following year, then have 120 days after receiving a deadline notice
The data - individual-level, for every employee
For all employees from the prior calendar year:
| Field | Detail |
|---|---|
| Gender | |
| Race and ethnicity | Per the state's categories |
| County of work | |
| Start date | |
| Total wages | Rounded to the nearest $100. The agency recommends using W-2 Box 5 |
| Hours worked | All compensated hours, including vacation and PTO |
| Hourly or salaried, and hourly rate | |
| Collective bargaining agreement coverage | |
| Job classification | Per the agency's categories |
Two of these are consistently painful. Hours worked including paid time off typically requires joining payroll and absence data that live in different systems. And an hourly rate for salaried employees has to be derived, not looked up.
Recent template change: the data template was revised in March 2025, adding three fields - paid hours, base hourly rate, and a collective bargaining indicator.
The Equal Pay Compliance Statement
Signed by a corporate officer, legal counsel, or authorised agent, certifying:
- Compliance with the state equal pay act and other applicable pay and anti-discrimination laws
- That average compensation for female and minority employees is not consistently below average compensation for male and non-minority employees within each job category
- That the business does not restrict job classifications by sex
- That wage disparities are corrected when identified
- How often wages are evaluated and how compensation is set
Penalties
Civil penalties of up to $10,000 per violation, escalating with the number of days to cure.
The agency may reject, suspend or revoke a certificate for failure to file or recertify, for non-compliance, for two or more final violations, or for falsification.
The process is progressive: a Notice of Noncompliance giving 30 days to comply, then a Notice of Violation with escalating fines. Rejections get an informal appeal; suspensions, revocations and penalties get an administrative hearing.
Coming change
The "prefers not to identify" option for race and sex data is being removed effective January 1, 2027. Employers relying on that option will need a different approach to employees who decline to self-identify.
Frequently asked questions
Is the threshold 100 employees nationally or in Illinois?
In Illinois. Plus fully remote employees who report to Illinois management.
How often do we recertify?
Every two years from the date your last certificate was issued.
What does it cost?
$150 per submission.
Is the data aggregated like California's?
No. Illinois collects individual-level records for every employee.
Which wage figure should we use?
The agency recommends W-2 Box 5, rounded to the nearest $100.
Do hours worked include PTO?
Yes - all compensated hours, including vacation and paid time off.
Who signs the compliance statement?
A corporate officer, legal counsel, or authorised agent.
What's the penalty?
Up to $10,000 per violation, plus possible suspension or revocation.
This guide is general information about reporting requirements, not legal advice. Verify current deadlines, thresholds and penalty amounts against the issuing agency before you file.