The Illinois Equal Pay Act requires all private businesses with at least 100 Illinois employees to obtain an Equal Pay Registration Certificate (EPRC) by March 23, 2024.

To obtain a certificate, businesses must pay a $150 filing fee, complete a compliance statement, and provide a wage records report containing detailed pay information.

Many businesses in Illinois have already received a notice from the Illinois Department of Labor (IDOL) requiring an EPRC submission before March 23, 2024. However, the Act and the IDOL’s FAQs make clear that any failure by the IDOL to assign a business an EPRC registration date does not exempt the business from completing a submission by March 23, 2024.

The first step for any businesses that have not yet submitted an application is to determine if they are implicated by the Act. The primary threshold questions are: (1) whether the business is required to file an annual Employer Information Report EEO-1 with the Equal Employment Opportunity Commission; and (2) whether the business had at least 100 employees who worked at a location in Illinois or were remote but reported directly to Illinois management on Dec. 31, 2023. Businesses that meet these threshold requirements will then need to register with the state and submit an application.