LawFlash

Recent final regulations made a series of 2021 amendments to the Illinois Equal Pay Act effective as of December 22, 2022. The amendments generally require private employers with 100 or more employees in the State of Illinois to obtain an “equal pay registration certificate” from the Illinois Department of Labor and expand certain reporting requirements, making the law one of the most far-reaching state equal pay laws in the United States.

Illinois Governor Pritzker signed into law amendments to the Illinois Equal Pay Act (IEPA), as well as certain other laws, on March 23, 2021. On June 25, 2021, the state further amended the IEPA with substantive changes, including an expansion of certain reporting requirements. Now, 18 months later, the Illinois Department of Labor (IDOL) has adopted final regulations implementing these amendments to the IEPA.

SUMMARY OF PRINCIPAL IEPA CERTIFICATION REQUIREMENTS

In sum, a private employer “business” that has 100 or more employees in the State of Illinois is required to obtain an “equal pay registration certificate” from the IDOL by filing an application with the agency between March 24, 2022, and March 23, 2024, and recertifying every two years thereafter.

The application date for each business will be determined by the IDOL. After collecting contact information from existing businesses, the IDOL will assign each covered business a deadline by which it must apply for the equal pay registration certificate. Importantly, under the...

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