Employers with 100 or more employees located in Illinois must renew their Equal Pay Registration Certificate (EPRC) every two years. For employers that obtained their initial EPRC in 2023, this means the deadline for renewing their certification falls in 2025.
Employers who have already obtained their initial EPRC should receive an automated reminder from the Illinois Department of Labor (IDOL) prior to the deadline for renewing their EPRC.
Details
By way of background, the state amended the Illinois Equal Pay Act (IEPA) in 2021 to require that private employers report certain payroll information to the IDOL and obtain an EPRC. The requirement applies to any private employer that has 100 or more employees residing in Illinois and is required to file an annual EEO-1 with the U.S. Equal Employment Opportunity Commission (EEOC). The EPRC must be renewed every two years.
To obtain/renew an EPRC, covered employers must certify, among other things, that the average compensation for their female and certain other employees isn’t consistently below the average compensation for their counterparts within each of the major job categories in the EEO-1, taking into account factors such as:
· length of service
· job requirements
· experience
· skill
· effort
· responsibility
· working conditions
· education or training
· job location
· a collective bargaining agreement
· or other mitigating factors
New Data Elements for 2025
Beginning in 2025, employers must also include the following information in their EPRC application:
- Whether the employee is paid on an hourly or salary basis
- If the employee is paid on an hourly basis, the hourly rate
- Whether the employee is covered by a collective bargaining agreement
Additionally, the IDOL has added “Middle Eastern and North African” (MENA) as another option for identifying employee race. Employers may include MENA information if they have already collected this data, however, employers are not obligated to start soliciting this information for 2025 reporting.
The IDOL has updated its EPRC template and answers to frequently asked questions to reflect the changes. The portal for submitting an EPRC renewal application is now open.
Process for Reporting
Most employers that are subject to the EPRC requirements were contacted by the IDOL and provided a deadline for initial registration in 2023 or early 2024. Under the IEPA, even if the IDOL hadn’t contacted an employer, they still had a statutory obligation to complete their initial EPRC submission by March 23, 2024.
The IDOL has announced that employers who were due to submit their renewal applications from January 1, 2025 through March 30, 2025 will have until March 31 to do so, unless a further extension is granted.
Next Steps
If you have 100 or more employees residing in Illinois and are required to file an annual EEO-1 with the EEOC, make sure you comply with the EPRC requirements by the applicable renewal deadline.