Illinois Amends Equal Pay Act to Separate It from Federal EEO-1 Reporting

Effective June 30^th, Illinois has amended their Equal Pay Act to remove references to the EEO-1 Annual Employer Information Report. References to the EEO-1 report and the EEOC itself have been removed in 4 places. A “business” now only needs to be a private employer who has 100 or more employees in the State of Illinois. Reference to the business being required to also have filed an Annual Employer Information Report EEO-1 with the Equal Employment Opportunity Commission have been removed.

Of particular note, although the job categories have remained the same, they are now given a specific definition within this law and are no longer formally based upon ‘the major job categories in the Employer Information Report EEO-1’. References to ‘skilled’, ‘semi-skilled’ and 'unskilled’ labor have also been removed from the job category titles, as seen in the EPRC (equal pay registration certificate) employee import template.

The choice to keep the job categories names the same adds to the striking nature of removing the EEOC and EEO-1 references. Removing any connection to these source materials can be seen as a proactive strategy against any potential concerns to the longevity and rigidity that these pillars hold for the future. The Illinois government has chosen to be proactive in safeguarding the original meaning of their reports, lest there be federal changes outside their control.

While these changes may signal a heightened acknowledgement of the shifting climate, they will not lead to a difference in how the EPRC employee template is completed. Companies must submit their data and attest to the compliance requirements every two years. Berkshire can provide support for the IL EPRC submission process, from preparing your file to conducting proactive statistical analysis of your data ahead of your submission to supporting your organization through questions by the IL DOL. For more information, contact your Berkshire consultant or reach out to us on our People Insights page.