Illinois Pay Reporting Update

By: Sally Makreff, Bill Osterndorf, Kate Hayek

The deadline for Illinois pay reporting was March 23, 2024. Organizations covered by the pay reporting provisions of the Illinois Equal Pay Act were required to complete an application for an Illinois Equal Pay Reporting Certificate (EPRC) by that date if they had not previously completed an EPRC. The Illinois Department of Labor (IDOL) is currently reviewing applications submitted by the deadline. 

Covered organizations were required to complete an EPRC application in the EPRC portal. Organizations that have completed the application can see the status of their submissions in the portal. Applications will show a submission status of “pending” until a certificate is issued. 

Several organizations that recently filed the EPRC application have reported seeing a due date of May 6, 2024 associated with their filings. It is not clear what this May 6 due date means. There is no provision in the Equal Pay Act, its supporting administrative code, or IDOL frequently answered questions (FAQs) that mentions this May 6 date. The Equal Pay Act is very clear that covered employers were required to file an EPRC application by March 23, 2024. 

Covered employers that fail to meet the requirements regarding the EPRC may be fined up to $10,000. There is a provision in the Equal Pay Act which says that a covered employer who “inadvertently fails to file an initial application…shall be provided 30 calendar days by [IDOL] to submit the applicant…”  It remains unclear what the May 6 due date found in the portal means to covered employers that have already filed and to covered employers that have not filed. 

DCI will continue to monitor this situation and provide updates on IDOL’s activities as they occur. 

Sally Makreff

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