Are you ready for the Illinois Pay Transparency Deadline?

Strong points

  • Compliance deadlines for Illinois equal pay law changes fast approaching

  • Employers with more than 100 employees must meet the new requirements by March 23, 2023, unless the business began operations after March 31, 2021

  • Other states are creating pay transparency laws for private employers to ensure pay equity among employees regardless of gender, race or ethnicity

In 2021, Illinois announced changes to its Equal Pay Act of 2003 to ensure pay equity among employees and prohibit pay discrimination based on gender or racial identity.

Any former employer with 100 or more employees in Illinois who is required to submit an annual EEO-1 report to the Equal Employment Opportunity Commission is now required to submit an application to the Department of Labor to Illinois to obtain an equal pay registration certificate.

Other states have followed suit, and some application deadlines are approaching.

In Illinois, the application includes:

  • The latest EEO-1 report filed by the employer

  • A complete list of employees over the past calendar year, separated by gender, race, and ethnicity, along with the employee’s start date, county where work is performed, and wages for the past year

  • A signed Equal Pay Compliance Statement evidencing the employer’s compliance with applicable civil rights laws and specific requirements of Illinois law with respect to average wage equity, or corrections to achieve fairness; equitable access to job classifications and opportunities for retention and promotion; and how wages and benefits are assessed and discrepancies corrected.

Employers authorized to operate in Illinois after March 31, 2021 must submit an application within the first three years of operation, but no earlier than January 1, 2024. Those authorized to operate in Illinois no later than January 31, 2024. March 2021 must file their application between March 24, 2022 and March 23, 2024. If employers have multiple locations in the state, only one Application for Certification of Registration is required.

Colorado, Connecticut, and Nevada already have laws that require private employers to provide some level of pay transparency. Other states join us:


The first state to legislate pay transparency, the California legislature has passed a new law requiring employers with 15 or more employees in the state to post pay scales, including third parties the employer hires for job offers. ‘use. Employers with more than 100 employees in the state must also demonstrate their average and median compensation data by gender, ethnicity and racial categories. This legislation awaits Governor Gavin Newsom’s signature. If signed, it will enter into force on January 1, 2023.

New York

In New York state, statewide pay transparency legislation requiring employers to disclose the pay range in job postings awaits Governor Kathy Hochul’s signature. Ithaca, New York and Westchester County have already passed legislation requiring employers and employment agencies to include maximum and minimum wages when posting jobs, promotions or transfer opportunities. Compliance deadlines for these cities and counties differ, but all will come into effect before the end of 2022.

Rhode Island

Effective January 1, 2023, employers must provide salary ranges to job applicants who request the information and to employees at the time of hire, at the request of the employee, or when an employee changes positions.


Effective January 1, 2023, Washington State employers with 15 or more employees must disclose on job postings the pay scale, including a description of all benefits and other compensation.

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