Illinois Becomes Latest State to Require Pay Transparency in Job Advertisements
Employers Must Include Pay Range, Benefits & Promotional Opportunity Disclosures
Effective January 1, 2025, Illinois joins a growing number of states requiring inclusion of pay range and benefits information in job postings. Illinois also joins Colorado as the only other state (for now) requiring notice in certain circumstances to employees about “opportunities for promotion.”
While the new law is vague in some important areas (Illinois DOL will publish regulations that will hopefully clarify some of the “grey areas”), the available details, for now, include:
Pay Scale & Benefits in Job Postings
Applies to:
- Illinois employers with 15 or more employees;
- All job postings (external & internal) an employer elects to post - but postings are not required;
- If there is no job posting, the employer must disclose the pay scale and benefits to applicants "prior to any offer or discussion of compensation and at the applicant's request";
- "Pay Scale" means the wage or salary, or the wage or salary range, the employer reasonably expects to pay for the posted position;
- Requires a general description of the benefits and other forms of non-base compensation reasonably expected to be paid for the position;
- A hyperlink to the webpage including the pay scale and benefits information is acceptable.
Notice of Opportunities for Promotion
- Appears to apply only to job openings that are posted externally;
- Requires notice to all current employees of promotional opportunities no later than 14 calendar days after an employer advertises a job externally;
- Notably, the new law does not define "opportunities for promotion" or specify the contents of the required notice. However, this notice requirement does not apply to positions "exempt from competitive selection".
Other Limitations:
Notably, both these new transparency requirements apply only to jobs that "will be":
- Physically performed "at least in part" in Illinois, or
- Physically performed outside Illinois where the employee "reports to a supervisor, office, or other work site in Illinois."
- The "will be" language suggests that neither of these notice requirements applies where a remote job - posted as remote - might end up being performed in Illinois, but the employer does not require it and the job will not report into Illinois.
As differing state pay transparency laws proliferate, a proactive strategy, particularly for multi-state employers, becomes imperative. If you have questions or want to discuss options and best strategy for compliance, please reply to this email or reach out to the Silberman Law professional with whom you work.
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Since 1966, private employers with 100 or more employees have been required to annually file EEO-1 reports, requiring employers to submit the race/ethnicity and sex of each of its employees by EEO job category and workforce location. Similarly, non-private entities have been required to file EEO-2, EEO-3, EEO-4, or EEO
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