Illinois has established comprehensive wage transparency requirements designed to promote pay equity and provide workers with essential compensation information. The Illinois pay transparency law includes salary posting mandates, wage discussion protections, and additional compliance requirements such as Equal Pay Registration Certificates for larger employers.
Here’s what you need to know about Illinois’s pay transparency requirements and how they position the state among leaders in wage equity legislation.
Core Law & Compliance
What Is the Illinois Pay Transparency Law? (2025 Update)
Illinois’s pay transparency framework is built around several key components found in the Illinois Equal Pay Act, specifically 820 ILCS 112. The law requires employers with 15 or more employees to include pay scales and benefits information in job postings, while also establishing broad wage discussion protections for all employees.
The legislation requires covered employers to proactively disclose compensation information in job postings for positions that will be performed at least partly in Illinois, as well as remote positions that report to supervisors or offices within the state.
Additionally, Illinois mandates that employers with 100 or more employees obtain an Equal Pay Registration Certificate (EPRC), creating an additional layer of compliance for larger organizations. The law also establishes comprehensive record-keeping requirements and internal posting obligations for promotional opportunities.
Illinois Salary Posting Requirements for Employers
Under 820 ILCS 112/10(b-25), employers with 15 or more employees must include specific compensation information in all covered job postings. This includes the pay scale and benefits that the employer reasonably expects in good faith to offer for the position.
The requirement applies to job postings for positions that will be physically performed at least partly in Illinois, as well as remote positions that would report to a supervisor or office located within the state. Employers can satisfy this requirement by including the information directly in the posting or by providing a link to a page containing the required details.
For current employees, employers must make promotional opportunities known to all employees no later than 14 days after making external postings for those positions, ensuring internal candidates have access to advancement opportunities.
When Did/Does the Illinois Pay Transparency Law Take Effect?
Illinois’s pay transparency provisions have been implemented as part of the state’s ongoing commitment to wage equity. The salary posting requirements under 820 ILCS 112/10(b-25) represent a significant expansion of Illinois’s transparency framework.
Employers should ensure current compliance with all provisions, as the law includes robust enforcement mechanisms and penalties for violations. The Equal Pay Registration Certificate requirement for larger employers adds an additional compliance timeline that covered organizations must meet.
Employer Responsibilities
Which Employers Must Comply With the Illinois Pay Transparency Law?
Illinois pay transparency requirements apply to different categories of employers based on their size and the specific obligations involved.
All Illinois employers, regardless of size, must comply with basic wage notification requirements at hire (820 ILCS 115/10) and wage discussion protection provisions (820 ILCS 112/10(b)). These universal protections ensure that even small businesses cannot retaliate against employees for discussing wages.
Employers with 15 or more employees face additional requirements, including salary posting mandates and internal promotion notification obligations. Employers with 100 or more Illinois-based employees must also obtain and maintain an Equal Pay Registration Certificate.
Illinois Pay Transparency Thresholds by Employer Size
Illinois uses a tiered approach based on employer size:
- All Employers: Must provide wage notification at hire, maintain wage discussion protections, and keep required employment records (820 ILCS 115/10, 820 ILCS 112/10(b))
- Employers with 15+ Employees: Must include pay scales and benefits in job postings and notify employees of promotional opportunities within 14 days of external posting (820 ILCS 112/10(b-25))
- Employers with 100+ Illinois Employees: Must additionally obtain an Equal Pay Registration Certificate (820 ILCS 112/20)
The graduated system ensures that smaller employers face manageable compliance obligations while larger organizations with greater resources meet enhanced transparency requirements.
Penalties for Violating the Illinois Pay Transparency Law
Illinois enforces its pay transparency requirements through a comprehensive penalty structure designed to ensure meaningful compliance. Employers who violate wage discussion protections face potential liability for damages to affected employees.
The law prohibits retaliation against employees who discuss or disclose wage rates, with violations potentially resulting in reinstatement, back pay, and other appropriate remedies for affected workers.
Failure to comply with salary posting requirements, Equal Pay Registration Certificate obligations, or record-keeping mandates can result in enforcement action through the Illinois Department of Labor and additional penalties as provided under the Equal Pay Act.
Employee Rights & Impact
What Employees Should Know About the Illinois Pay Transparency Law
Illinois employees benefit from comprehensive protections under the state’s pay transparency framework. All workers have explicit rights to discuss and disclose their wage rates without fear of employer retaliation, regardless of their employer’s size.
Job seekers benefit from salary posting requirements that provide upfront compensation information for positions at employers with 15 or more employees. This transparency allows candidates to make informed decisions about job opportunities and enhances their negotiating position.
Current employees at covered employers have rights to advance notification of promotional opportunities, ensuring they can compete for internal advancement on equal footing with external candidates.
Employee Rights Under Illinois Salary Posting Law
Illinois’s salary posting law grants employees several specific rights designed to promote transparency and equal access to opportunities.
The fundamental right to wage discussion means employees can freely share salary information with colleagues, inquire about compensation practices, and seek information about pay equity within their organization without facing adverse employment actions.
Job applicants have the right to receive pay scale and benefits information for positions at covered employers, either directly in job postings or through linked pages containing the required details.
Current employees have the right to learn about promotional opportunities through internal notifications that must occur within 14 days of external postings, ensuring fair access to advancement opportunities.
How the Illinois Pay Transparency Law Helps Reduce Wage Gaps
Illinois’s comprehensive approach to pay transparency directly addresses multiple factors that contribute to wage gaps. The salary posting requirements help eliminate information asymmetries that often disadvantage certain groups during salary negotiations.
Strong wage discussion protections enable employees to identify potential pay disparities within their organizations and take appropriate action to address them. When workers can freely discuss compensation, patterns of discrimination become more visible and actionable.
The Equal Pay Registration Certificate requirement for larger employers creates additional accountability measures, while the internal promotion notification requirements ensure that advancement opportunities are accessible to all qualified employees.
HR & Legal Best Practices
How HR Teams Can Comply With Illinois Pay Transparency Law
HR teams should implement comprehensive compliance procedures covering all aspects of Illinois’s pay transparency requirements.
Begin with a thorough audit of current job posting practices to ensure all required compensation information is included for covered positions. Develop standard templates that include pay scales and benefits information, either directly or through appropriate links.
Establish clear procedures for internal promotion notifications, ensuring that all employees receive timely notice of advancement opportunities. For larger employers, ensure Equal Pay Registration Certificate applications are submitted and maintained according to state requirements.
Implement robust record-keeping systems to maintain required documentation for the mandated five-year period, including employee information, wage records, pay scales, benefits information, and job postings.
Updating Job Postings to Meet Illinois Salary Transparency Rules
Job postings for covered positions must include comprehensive compensation information that accurately reflects what the employer reasonably expects to offer in good faith.
Pay scale information should provide meaningful ranges that reflect the actual compensation structure for the role, considering factors like experience, qualifications, and performance. Benefits information should detail significant components of the compensation package.
Employers can include this information directly in job postings or provide links to pages containing the required details. Ensure that linked pages are easily accessible and contain all necessary compensation information.
Update posting templates and procedures to ensure consistency across all covered positions and departments, maintaining compliance across the organization.
Does the Illinois Pay Transparency Law Apply to Remote or Hybrid Workers?
Illinois’s pay transparency law specifically addresses remote work arrangements in its coverage provisions. The salary posting requirements apply to remote positions that would report to a supervisor or office located in Illinois, extending protections to remote workers with Illinois-based management.
This means that even fully remote positions must comply with Illinois disclosure requirements if they report to Illinois-based supervisors, ensuring that remote workers receive the same transparency benefits as in-person employees.
Employers should ensure their compliance procedures account for all work arrangements and that remote and hybrid positions receive appropriate transparency treatment based on their reporting relationships and organizational structure.
Comparison and Broader Context
How Illinois Pay Transparency Rules Compare With California and New York
Illinois’s approach to pay transparency shares significant similarities with California and New York while maintaining distinct characteristics. Like both states, Illinois requires proactive salary disclosure in job postings rather than disclosure only upon request.
Illinois’s 15-employee threshold aligns closely with similar requirements in other leading transparency states, providing broad coverage while recognizing the compliance challenges faced by very small businesses.
The Equal Pay Registration Certificate requirement for larger employers represents a unique accountability measure that goes beyond what many other transparency states currently require, positioning Illinois as a leader in comprehensive pay equity enforcement.
Illinois’s internal promotion notification requirements also demonstrate the state’s commitment to ensuring transparency benefits extend beyond initial hiring to career advancement opportunities.
Federal Pay Transparency Requirements vs. Illinois Law
Illinois’s comprehensive state-level requirements significantly exceed current federal transparency protections. While federal contractors face certain disclosure requirements, Illinois’s law provides broader protections for private sector employees across various industries.
The state’s wage discussion protections supplement federal National Labor Relations Act provisions while extending specific penalties and remedies for violations. Illinois’s proactive salary posting requirements fill gaps in federal protection that may leave workers without adequate transparency rights.
Illinois’s framework demonstrates how state legislation can provide enhanced worker protections that exceed federal minimums, serving as a model for potential federal pay transparency legislation.
Pay Transparency Laws by State: Where Does Illinois Stand?
Illinois ranks among the leading states in comprehensive pay transparency legislation, with requirements that place it at the forefront of the national transparency movement. The state’s combination of salary posting mandates, wage discussion protections, and additional accountability measures creates a robust framework.
The 15-employee threshold provides broad coverage while remaining practical for enforcement, and the Equal Pay Registration Certificate requirement for larger employers demonstrates Illinois’s commitment to comprehensive oversight.
Illinois’s approach has influenced transparency legislation discussions in other states, with its balanced requirements and enforcement mechanisms serving as a model for effective pay transparency implementation.
FAQs About the Illinois Pay Transparency Law
Do small businesses need to comply with Illinois pay transparency law?
All Illinois employers must comply with basic wage notification requirements at hire and wage discussion protections, regardless of size. However, salary posting requirements and internal promotion notifications only apply to employers with 15 or more employees. The Equal Pay Registration Certificate requirement only applies to employers with 100 or more Illinois-based employees.
How should employers update existing job postings?
Employers with 15 or more employees must update all job postings for covered positions to include pay scales and benefits information. This can be included directly in the posting or through a link to a page containing the required details. The information must reflect what the employer reasonably expects to offer in good faith for the position.
Are salary ranges required for internal postings as well as external ones?
Illinois requires employers to notify all current employees of promotional opportunities within 14 days of making external postings, but the law doesn’t specifically require internal postings to include salary information. However, the transparency principles suggest providing comprehensive compensation information for internal opportunities as well.
What happens if employers fail to disclose salaries?
Employers who violate Illinois pay transparency requirements may face enforcement action through the Illinois Department of Labor, potential liability for damages to affected employees, and other penalties as provided under the Equal Pay Act. Violations of wage discussion protections can result in reinstatement, back pay, and other appropriate remedies for affected workers.
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