Illinois Equal Pay Registration Certificate: Filing, Fees, and Penalties

Every private employer with 100 or more employees in Illinois must hold an Equal Pay Registration Certificate from the Illinois Department of Labor. Meeting the Illinois Equal Pay Registration Certificate requirements means filing employee-level wage data, submitting a signed compliance statement certifying pay equity across sex and race, paying a $150 fee through the Department’s online portal, and renewing every two years. Missing the filing can cost up to $10,000 per violation.¹

Which Businesses Are Covered

The statute reaches any private employer with 100 or more employees in Illinois.² Government agencies, political subdivisions, and municipal corporations are excluded. Because the headcount is measured within the state, a national employer with 500 workers but only 80 in Illinois falls outside the requirement.

When a business first crosses the 100-employee threshold, it registers through the Department’s business survey and then has 120 days from the deadline it is given to complete the filing.³ The obligation applies whether or not the Department reaches out first. Not knowing about the requirement is not a defense.

The Wage Data You Have to Submit

The application starts with an employee-level dataset for the previous calendar year. For every employee, you provide gender, race and ethnicity categories, the county where the employee works, the employee’s start date with the business, and total wages paid during that year rounded to the nearest $100.² “Total wages” tracks the Illinois Wage Payment and Collection Act, so salary, overtime, bonuses, and commissions are all included.

You also submit your most recent federal EEO-1 report, which classifies your workforce across ten job categories by race and gender. If your organization is not required to file a federal EEO-1, you compile equivalent demographic data instead. The Department publishes Excel templates on its website to standardize submissions, and it cross-references the wage data against the compliance statement, so inconsistencies can trigger a rejection.

The Equal Pay Compliance Statement

A corporate officer, legal counsel, or authorized agent must sign a compliance statement containing six specific certifications.² This is where most of the analytical work sits.

The business complies with the Illinois Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Equal Pay Act of 1963, the Illinois Human Rights Act, and the Equal Wage Act.
Average compensation for female and minority employees is not consistently below average compensation for male and non-minority employees within each of the ten EEO-1 job categories, after accounting for legitimate factors such as length of service, experience, skill, education, job location, and use of a collective bargaining agreement.
The business does not funnel employees of one sex into certain job classifications, and retention and promotion decisions are made without regard to sex.
When wage or benefit disparities are identified, the business corrects them.
A description of how often the business evaluates wages and benefits.
An explanation of how the business sets wage and benefit levels for its employees.

The second certification is where employers get stuck. You do not have to show that every individual employee earns the same amount. The standard is that average compensation within each job category is not consistently lower for women or minorities, and legitimate business factors like seniority, specialized skill requirements, or production quality can justify gaps.³ Market rate at hire or historical practice tend to be weak justifications on their own. If your internal analysis surfaces unexplained disparities, correcting them before filing is usually the cleaner path.

Filing, Fee, and the Correction Window

Everything goes through the Department’s online EPRC portal. You upload the wage data in the Excel template, the signed compliance statement as a PDF, and your EEO-1 report, then pay the $150 non-refundable fee.⁴ The contact person on the account receives an automated confirmation.

You have 30 days from submission to repair data in the portal without paying another fee. After that window, any correction requires a new $150 payment.⁴ Review your file before submitting, and if you catch a mistake in the first month, fix it right away.

Review Timeline and Renewal

The Department must approve or deny each submission within 45 days.⁴ When wage data is incomplete or unreadable, EPRC staff will typically work with you before rejecting the application outright. Once issued, the certificate is valid for two years.³

Automated reminders arrive at 180 days and 60 days before expiration.⁴ Recertification uses fresh wage data and a new compliance statement, mirrors the initial filing, and costs another $150. Pulling accurate pay data across an entire workforce takes time, so the 180-day notice is the practical starting point.

If Your Application Is Denied

An application can be rejected for two reasons: it fails the requirements of Section 11, or the business is found to be in violation of the Illinois Equal Pay Act.⁴ After a rejection, you can revise and resubmit within 30 days without paying a new fee. Falsifying or misrepresenting information is itself a violation and can lead to suspension or revocation of an existing certificate along with civil penalties.

The statute also provides a right to administrative review of a denial.⁴ If you believe your data and compliance statement met the statutory requirements, you can challenge the decision rather than starting over.

Penalties for Missing the Filing

Enforcement runs on a graduated track. If your certificate lapses or you never file, the Department issues a Notice of Delinquency giving you 30 calendar days to submit.³ Continued non-compliance produces a Notice of Violation with penalties that scale with how long the deficiency runs, and then a Notice of Determination and Order that the Office of the Attorney General can enforce.

The maximum civil penalty is $10,000 per violation of Section 11.¹ The Department can also suspend or revoke an existing certificate. Paying the fine does not excuse the filing itself; you still have to obtain the certificate.⁴

Records You Must Keep

Any employer subject to the Equal Pay Act must keep records showing each employee’s name, address, occupation, wages paid, the pay scale and benefits for each position, and job postings, and must preserve those records for at least five years.⁵ This is broader than the EPRC filing and stands as its own enforceable obligation, but clean, organized compensation records are also what makes each renewal manageable.

Related Equal Pay Act Duties That Are Not the EPRC

The certificate is not the Equal Pay Act’s only obligation, and some rules apply to smaller employers than the 100-employee EPRC threshold. Since January 1, 2025, employers with 15 or more employees must include pay scale and benefits in any job posting for work performed at least partly in Illinois or reporting to an Illinois supervisor or office.⁵ Illinois also prohibits requesting or requiring salary history from applicants as a condition of consideration.⁶ And the Act protects employees who ask about, discuss, or compare wages with coworkers from retaliation.⁷ These are separate compliance tracks from the EPRC filing, but a business preparing its certificate should confirm it is meeting them at the same time.

1
Illinois General Assembly. Illinois Code 820 ILCS 112/30 – Violations; Fines and Penalties
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Illinois General Assembly. Illinois Code 820 ILCS 112/11 – Equal Pay Registration Certificate Requirements; Application
3
Illinois Department of Labor. Equal Pay Registration Certificate – FAQS
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Illinois Department of Labor. Equal Pay Registration Certificate
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Illinois Department of Labor. Equal Pay Act Salary Transparency
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Illinois Department of Labor. Equal Pay Act Salary History Ban FAQ
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Illinois General Assembly. Illinois Code 820 ILCS 112 – Equal Pay Act of 2003