Illinois Updated Employer Pay Reporting Standards
The state modified filing procedures to improve data validity and prepare for potential wage enforcement actions.
Updated on Sept. 30, 2026 in Employment
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The Illinois Department of Labor (IDOL) implemented changes to its Equal Pay Registration Certificate (EPRC) filing process in July 2026. These updates remove the option for employees to opt out of gender and race reporting to increase the precision of pay data submitted by employers.
Why it matters
By removing the ability for workers to decline self-identification, the IDOL seeks to gain a clearer picture of wage disparities across the state. This initiative follows a collaborative report with the University of Illinois that confirmed ongoing pay gaps between different demographic groups.
The IDOL established tiered pay gap risk thresholds ranging from 5 percent to 25 percent to categorize reporting data. Since 2022, employers have submitted 9,000 EPRC filings to the state agency.
The players
Illinois Department of Labor
This state agency oversees labor laws and workplace standards, including the enforcement of equal pay registration certificates.
University of Illinois Urbana-Champaign
This public research university partnered with the state to analyze labor data and identify wage disparity trends.
The details
Employers must now utilize internal personnel records or observer identification to classify employees who do not self-identify, replacing the previous option to mark 'prefers not to identify.' The agency also streamlined its administrative process for handling overdue filings from three steps down to two.
Timeline
The UIUC analysis covered data from 2021 to 2023.
The IDOL added the Middle Eastern or North African category in October 2025.
Notice regarding the updated filing requirements was issued in July 2026.
The agency will roll out a new EPRC reporting tool on January 1, 2027.
Submissions using the 'prefers not to identify' option will be rejected starting in January 2027.
Macro View
These reporting changes mark a shift in how Illinois executes the Illinois Equal Pay Registration Certificate (EPRC) requirement. The refinements mirror broader efforts by state labor agencies to tighten administrative reporting standards to mirror federal EEO-1 mandates.
Employers operating in Illinois must adjust their internal HR record-keeping processes to ensure they can provide required demographic data without relying on employee self-identification. Workers should be aware that their demographic info may now be classified by observers or through existing records if they choose not to disclose it.
The takeaway
The IDOL's shift toward stricter data collection signals an intent to move from passive reporting to active wage gap enforcement. Businesses should review their pay structures against the new risk tiers to ensure compliance ahead of future reporting deadlines.
What happens next
The IDOL will launch a new EPRC reporting tool on January 1, 2027, and will begin automatically rejecting any submissions that include the 'prefers not to identify' classification thereafter.
Further reading
For more information on state labor mandates, visit Illinois Employment.
Source note: This article includes information reported by The National Law Review - A Free To Use Nationwide Database of Legal Publications.
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