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New Illinois Employee-Level Pay Data Reporting Requirements

January 17, 2023
Megan Regennitter

In March 2021, the Illinois Legislature passed amendments to the Illinois Human Rights Act (the Act), 820 ILCS 112, making Illinois the first state to require the reporting of employee-level pay data. Beginning January 2023 through March 2024, initial Equal Pay Registration Certificate applications are required to be submitted to the Illinois Department of Labor (IDOL). Currently, IDOL is notifying covered employers via mail of their initial application due dates within this time frame, providing at least 120 days to submit the application.

The reporting and equal pay data publishing requirement applies to private employers with 100 or more employees. Reporting includes a list of all employees broken down by gender and race, similar to the employer’s most recent EEO-1 Report,[1] total wages[2] paid to each employee, and an Equal Pay Compliance Statement. Reports are made electronically on a biennial basis, for a current filing fee of $150.00.

IDOL is permitted to compile aggregate data and reports based on the wage data submitted by employers. These reports will not include any individually identifiable business or personal information. However, any current employee of a business required to report may request anonymized data regarding their job classification or title and the corresponding pay information. IDOL may also share data with the Department of Human Rights to ensure compliance with the Act.

Employers who fail to comply with the reporting requirements, or provide false or misleading information, may face fines of up to $10,000.

If you have any questions about your business’ reporting requirements, please reach out to Megan M. Regennitter, MWH Law Group LLP, at

[1] The EEO-1 Report is a required annual workforce demographic snapshot report to the EEOC for private employers (100 or more employees) and federal contractors (50 or more employees) with information such as job categories, ethnicity, race, and gender.

[2] Wages are defined pursuant to the Illinois Wage Payment and Collection Act, 820 ILCS 115, and include wages, commissions, bonuses, stocks, and ownership shares.


MWH Megan Regennitter

Megan M. Regennitter, Senior Associate
1501 42nd St. Suite 465
West Des Moines, IA 50266
P: (515) 453-8509 / F: (515) 267-1408