By Dave Sharrer
BLOG OVERVIEW: In 2025–2026, the Illinois Department of Labor (IDOL) issued several updates to the Equal Pay Registration Certificate (EPRC) program. Key changes include adding a "Middle Eastern or North African" (MENA) demographic category, removing the "prefers not to identify" option, formally decoupling the EPRC from the federal EEO-1 report under HB 2488, and moving the compliance statement online. Most significantly, Illinois has begun analyzing and publicly reporting aggregate EPRC pay data, making the accuracy of employer submissions more consequential than ever. Covered employers (100+ Illinois employees) must still re-certify every two years or face penalties up to $10,000.
Earlier this summer, the Illinois Department of Labor (IDOL) sent covered employers a consolidated notice summarizing updates implemented to the Illinois Equal Pay Registration Certificate (EPRC) throughout 2025 and 2026. For the most part, the core reporting framework remains unchanged. Many of the updates are administrative, including renamed notices, a streamlined submission portal, and final administrative rules reflecting the statutory changes enacted last year.
Changes Indicate Illinois is Closely Examining Collected Data
The most significant development provides a glimpse into how Illinois is using collected data. In December 2025, the University of Illinois Urbana-Champaign’s Project for Middle Class Renewal, in partnership with IDOL, released the first analysis of the aggregate data collected for the EPRC program. Drawing on millions of employee-level records submitted since 2021, the report examined gender- and race-based pay disparities among Illinois employers and found that the gender wage gap has narrowed while substantial racial disparities persisted.
For employers, this indicates that pay data submitted through the EPRC program is no longer simply being collected and stored as in past years. It is now being analyzed, published in aggregate, and used to inform public policy.
The analysis component makes the accuracy and defensibility of an employer’s submission increasingly consequential. Employers should be prepared to support their job classifications, demographic data, compensation records, and methods for identifying and addressing potential pay disparities. Conducting a privileged, proactive statistical review before submission can help employers understand what their data may reveal and enable them to address potential concerns before filing.
Other Changes to the EPRC
In addition to the analysis conducted by IDOL and the University of Illinois Urbana-Champaign, the following developments warrant closer attention:
- Changes to demographic reporting: IDOL added “Middle Eastern or North African” (MENA) as a race category effective October of 2025. As of July 2026, it also removed “prefers not to identify” as a reporting option. Employers that formerly permitted that response option should determine how they will address unknown demographic records before their next submission window.
- Administrative rules finalized: The statutory decoupling of the EPRC program from the EEO-1 report through Illinois HB 2488 took effect in June 2025, and IDOL finalized the corresponding administrative rule in June 2026. Importantly, the job-category definitions remain unchanged and continue to align with the major EEO-1 categories. As a result, the job classifications employers have already completed should generally remain valid and can be carried forward.
- Process and portal improvements: The Compliance Statement should now be completed online, eliminating the need to download, sign, scan, and upload the form. Employers can now also download previously approved submissions, and the portal will alert users to the 30-day period for correcting a rejected submission before a refiling fee applies. IDOL has also renamed its delinquency and violation notices to improve consistency across divisions.
More on the EPRC
Since 2024, all private employers in Illinois with 100 or more employees are required to obtain an equal pay registration certificate every two years. Employers that fail to certify may be subject to civil penalties of up to $10,000.
To obtain a certificate, employers must:
- Pay a filing fee of $150,
- Submit an "equal pay compliance statement,"
- Submit a copy of a report with a list of all employees, including total wages, separated by job category, gender, race and ethnicity categories.
DCI will continue to monitor EPRC developments in Illinois and other evolving state pay-data reporting requirements. Stay tuned to the DCI Blog for more updates.
