The Illinois Department of Labor (IDOL) has issued final regulations and FAQs implementing the Illinois Equal Pay Act Amendments. The IDOL has suspended the requirement to file an EEO-1 Report with the Department. The IDOL adds requirements for employers, defines key terms, explains the Equal Pay Registration Certificate application process, including the new requirement for including hours worked for all employees, enumerates compliance steps and discusses risks of non-compliance.

The Illinois Department of Labor recently published final regulations governing the new requirements for employers to comply with the Illinois Equal Pay Act Amendments (the “EPA Amendments”) signed into law by Governor Pritzker on March 23 and June 25, 2021. The EPA Amendments make the Illinois Equal Pay Act one of the most demanding pay transparency statutes in the country because it requires employers with 100 or more employees in Illinois to submit employee pay data and a signed compliance statement to obtain an Equal Pay Registration Certificate (EPRC).¹

After a significant public comment period, the final regulations were published in January 2023, effective as of December 22, 2022. While the regulations clarify the IDOL’s expectations for employers subject to the EPA Amendments, they also raise additional questions because of inconsistencies with the statute and information provided on the IDOL website. Below are some of the key takeaways and recommendations for employers:

The...

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