The Illinois Department of Labor (IDOL) recently sent a communication to businesses that have previously interacted with the state’s Equal Pay Registration Certificate (EPRC) program. The communication highlighted several key enhancements to the EPRC portal, as well as other program updates. In this compliance alert, we look at the most important of these updates—including EPRC data collection enhancements and the state’s efforts to decouple the EPRC from federal reporting.
Summary
If your organization has previously interacted with the Illinois Department of Labor (IDOL) due to participation in the State’s Equal Pay Registration Certificate (EPRC) program, you’ll have recently received an email summarizing eight recent and pending changes between August 2025 and January 2027.
Private businesses with 100+ Illinois employees must submit certain information on their pay practices and employee pay data biennially, along with a $150 fee. This is done via a dedicated portal, and results in the issuance of an EPRC certificate. IDOL indicates that around 9,200 EPRC submissions have been made since the program began in 2022.
The changes in the recent communication include:
- A streamlined EPRC submission procedure that supports digital signing of documents, ensuring the entire process can be completed online. [Effective August 2025]
- Enhanced EPRC data collection via additional race options [effective October 2025] and new rules regarding the “chooses not to identify” option [effective July 2026]
- Decoupled EPRC from federal pay data reporting by removing all statute and rule references to EEO-1. Previously, submissions were dependent on whether and what a business reported on the federal EEO-1. [effective June 2026]
- Improvements in EPRC portal self-service, including the ability to download prior IDOL-approved submissions, and an added warning about the 30-day deadline for making revisions to rejected submissions. [effective July 2026]
Other announcements summarized in the communication included the renaming of the “Conciliation/Mediation” division of IDOL to “Wage Transparency and Construction Compliance”, some refinements of terminology in IDOL notices, and the release of a Comprehensive Evaluation and Policy Recommendations report.
Updates to the EPRC’s revised pay data reporting tool, including updated race, ethnicity, and gender options, will be available in January 2027.
Who Is Impacted and What Actions Are Required?
Organizations that fall within the 100+ Illinois employee threshold and therefore require certification will need to pay particular attention to the new requirements around missing gender and race data.
In previous years, IDOL found that some businesses were skewing data collection because of a large number of “chooses not to identify” selections under employee race, gender, and/or ethnicity. In a recent FAQ, IDOL has clarified that it may reject an EPRC submission if it contains multiple “chooses not to identify” entries for these fields.
The FAQ directs organizations to use employment records or observer identification in place of employee self-identification. Information obtained in this way should be kept separately from the employee’s basic personnel file, as well as any other records available to those responsible for personnel decisions.
Organizations should also bear in mind that EPRC requirements may now apply to them regardless of their Federal EEO-1 filing status.
How Affirmity Can Help
Affirmity provides state-level pay data reporting and file submission support services, as well as software, for the growing number of states that require it. Furthermore, our compensation and pay equity analysis services provide proactive protection against potential EEOC lawsuits, identifying and correcting potential patterns of disparity and adverse impact as your workforce evolves.
Affirmity is on hand to help you deliver pay equity and address the issues you proactively uncover—contact us today to get started.
About the Author
Colleen Hanson serves as a Business Consultant at Affirmity, where she has spent four years supporting clients across workforce analytics, HR compliance, and affirmative action planning. She brings a decade of experience in HR, compensation, and recruiting, giving her a well-rounded perspective on the complexities her clients face. Colleen works closely with clients to deliver tailored compliance consulting and workforce reporting solutions. She holds a Bachelor’s degree in Human Resource Management and a Master’s degree in Organizational Development and Leadership.