Minnesota Equal Pay Certificate
Minnesota's Equal Pay Certificate is a contractor prequalification requirement, not a general employer mandate. It applies only when a covered business enters a covered contract - which makes it structurally different from Illinois's certificate or California's pay data report.
Administered by the Minnesota Department of Human Rights.
Who needs one?
Both conditions must be met.
Size: the business has 40 or more full-time employees - in Minnesota, or in the state where it has its primary place of business - on a single day during the 12 months prior to executing the contract.
Contract value:
| Contracting entity | Threshold |
|---|---|
| State agency | Contracts exceeding $500,000 |
| City, county or other political subdivision | Contracts exceeding $1,000,000 - general obligation bond-funded capital projects |
| University of Minnesota | Contracts exceeding $500,000 - general obligation bond-funded capital projects |
Note the size test can be satisfied by employees outside Minnesota if that's where the business has its primary place of business. An out-of-state contractor with 40+ employees at home qualifies even with a small Minnesota presence.
What's required
- An online application
- Proof of the $250 fee
- A compensation report disclosing how the business sets pay - market pricing, prevailing wage, performance pay, internal analysis, or another method
- A statement signed by the chairperson or chief executive officer certifying:
- Compliance with federal and state equal pay and anti-discrimination law
- That average compensation for female employees is not consistently below average compensation for male employees within each of the major job categories
- That the business does not restrict job classifications by sex
- That wage disparities are corrected promptly when identified
- That wages and benefits are evaluated regularly
The commissioner reviews within 15 days of receipt.
Validity and penalties
A certificate is valid for four years - considerably longer than Illinois's two-year cycle, reflecting that it's tied to contracting rather than to ongoing operations.
Penalties: fines up to $5,000 per calendar year for each contract, plus suspension or revocation of the certificate. An administrative hearing may be requested within 20 days of notice.
How it compares
| Minnesota | Illinois | |
|---|---|---|
| Trigger | Winning a covered contract | Operating with 100+ in-state employees |
| Threshold | 40 full-time employees | 100 employees |
| Data | Compensation methodology | Individual-level records for every employee |
| Validity | 4 years | 2 years |
| Fee | $250 | $150 |
Minnesota asks how you set pay. Illinois asks what you actually paid every individual. They're different obligations that happen to share a name.
Frequently asked questions
Do all Minnesota employers need this?
No. Only businesses meeting the size test that are entering a covered contract.
What's the size threshold?
40 or more full-time employees on a single day in the 12 months before executing the contract - in Minnesota or in the state of the primary place of business.
What are the contract thresholds?
Over $500,000 for state agency and University contracts; over $1,000,000 for political subdivision bond-funded capital projects.
How long is it valid?
Four years.
What does it cost?
$250.
Do we submit employee-level data?
No. A compensation report describing methodology, plus a signed statement.
Who signs?
The chairperson or chief executive officer.
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.