By Dave Sharrer & Kate Hayek
Earlier this year, the Illinois Department of Labor (IDOL) announced changes to its Equal Pay Registration Certificate (EPRC) filing process. On June 30, 2025, Illinois Governor J.B. Pritzker signed HB2488 into law, amending the Equal Pay Act of 2003 (the Act) and further refining EPRC requirements. The most significant changes include:
- Removing all references to the federal EEO-1 report from the Act in response to January's Executive Order 14173, which affected reporting thresholds for federal contractors. Previously, the Act applied to employers with 100 or more employees who were also required to file the EEO-1 report. With the removal of references to the EEO-1 report, the Act now applies to any private employer with 100 or more employees in the State of Illinois as of December 31.
- Changes to the required compliance statement. Employers previously certified that “the average compensation for its female and minority employees is not consistently below the average compensation for its male and non-minority employees within each of the major job categories in the Employer Information Report EEO-1.” The amended law replaces the italicized portion with “job category.”
Additionally, HB2488 clarified terms related to “(general) prevailing rate of hourly wages” as meaning “hourly cash wages plus full journeyman annualized fringe benefits for training and apprenticeship programs registered with the Office of Apprenticeship within the U.S. Department of Labor’s Employment and Training Administration with full journeyman annualized fringe benefits…”
For most employers, the impact should be minimal because “job category” as defined in HB2488 aligns with the job categories found in the EEO-1 report, which were already included in the template published by IDOL earlier this year. However, HB2488 reflects a growing trend of states responding to changes on the federal level.
DCI will continue to track developments in Illinois and beyond.
