Private employers with one hundred or more Illinois employees must file EEO-1 reports, as well as obtain an Equal Pay Registration Certificate (EPRC) from the Illinois Department of Labor (IDOL). This certification must be renewed every two years, with the announcement in February 2025 that IDOL has made updates to the EPRC application process with a new data template.
This new data template must be used by all employers with 100 or more employees in Illinois who are required to file an EEO-1 with the EEOC. This includes those who are seeking to recertify and those who are submitting an initial EPRC certification for the first time.
Initially, IDOL emailed employers due to recertify in early 2025 with a notice to pause on submissions while they updated the submission portal and filing requirements. This revised data template became available on the EPRC page of the Department’s website on March 10th and the system began rejecting any submissions made with the old template on March 17th.
The portal has been made live for applications as of 9:30am on March 21st. IDOL set the deadline for paused recertification submissions to be submitted by March 31, 2025, but extensions may also be requested.
Along with moving to an online fillable form with DocuSign, the new application requires three new data fields:
Example images can be found in their slide presentation here.
These changes follow an amendment to the Illinois Equal Pay Act that went into effect on January 1 of this year, requiring the inclusion of pay scale and benefit information in job postings. This amendment brought greater transparency to job applicants about what compensation and benefits will be offered. At the same time, Illinois has also amended their Wage Payment and Collection Act (IWPCA) to require employers to provide pay stubs for each pay period, adding numerous new recordkeeping obligations with it.
The changes to the data template reflect that IDOL is trying to enhance its use of the data collected. Previous iterations of the EPRC only required the inclusion of wages paid in the previous calendar year to be listed for each employee. This format did not clearly set froth the hourly wage rate for non-exempt workers, which likely made it difficult for IDOL to evaluate pay differences.
In its first webinar on the new data collection template, IDOL also noted increased enforcement efforts, issuing only 15 notices of violations in FY 2024 and over 60 notices of violations for FY 2025 as of February 13, 2025. IDOL also provided information about the number of EPRC registrations between 2022 and 2024, with the numbers suggesting many employers will be required to submit their two-year renewal in 2025 and early 2026.
Now is the time for employers to begin to prepare for this filing. Berkshire’s People Insights team can help you evaluate the pay data you submit for certification.