Illinois Tightened Pay Data Reporting Standards

Employers must adjust data collection processes for the state's equal pay registration certificate requirements.

Updated on Sept. 30, 2026 in Employment

Isometric editorial illustration of stacked geometric filing containers, representing organized data submission under new state labor compliance requirements. — Illinois labor officials have updated pay reporting standards, requiring employers to use internal personnel records to classify employees in registration filings. AI Illustration. Upload story photo >

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The Illinois Department of Labor recently updated its Equal Pay Registration Certificate (EPRC) submission standards by removing the option for employees to decline identification. These changes require employers to classify employees using internal records to ensure data accuracy as the state moves toward stricter enforcement.

Why it matters

The updates aim to address wage gaps identified in a review of 2021 to 2023 pay data by increasing the validity of employer filings. Operators face heightened compliance requirements as the state integrates these findings into its enforcement strategy.

The IDOL has collected 9,000 EPRC submissions since 2022 and now classifies wage gaps into tiers, ranging from a 5 percent to 15 percent informational threshold to a 25 percent high-risk designation.

The players

Illinois Department of Labor

The state agency responsible for enforcing labor standards and managing the Equal Pay Registration Certificate program.

University of Illinois Urbana-Champaign

A public research university that partnered with the state to analyze multi-year pay data for wage gaps.

The details

To comply with the updated CSV upload process, businesses must now categorize any employee who declines to self-identify by using existing personnel records or observer identification. The agency has also streamlined the administrative appeals process for overdue filings from three steps down to two. These moves support the agency's broader goal of utilizing pay disparity data for future enforcement actions.

2021-2023: Period covered by the University of Illinois Urbana-Champaign analysis report.
October 2025: Added Middle Eastern or North African as a reporting category.
July 2026: IDOL issued the formal notice regarding the updated EPRC filing requirements.
January 1, 2027: Planned rollout date for the new EPRC reporting tool.
January 2027: The system will begin rejecting submissions containing the 'prefers not to identify' option.

Market Landscape

These standards update the operational procedures required by the Illinois Equal Pay Registration Certificate mandates. The state is intensifying oversight to align with broader trends in pay transparency and anti-discrimination enforcement.

HR departments must transition from relying on employee self-identification to an administrative classification process for all staff. Operators should review their existing payroll data against the state's 5 percent to 25 percent risk tiers to gauge potential exposure to future agency enforcement.

The takeaway

The IDOL is moving toward a mandatory data model that leaves no room for non-response, signaling a shift toward aggressive verification of pay equity filings. Review your 2021-2023 pay data now to identify if your current wage structures fall within the state's defined risk tiers.

What happens next

Employers should prepare for the January 1, 2027, rollout of the new reporting tool and ensure internal HR data collection processes are updated to classify all employees before the January 2027 system changes take effect.