Illinois Pay Transparency Law 2025: Job Posting Requirements

Illinois amended its Equal Pay Act via HB 3129, requiring employers with 15 or more employees to include pay scale and benefits information in job postings starting January 1, 2025. The law also adds an internal posting requirement — open roles must be shared with existing employees, similar to Colorado’s EPEWA.

Quick facts

Law

Illinois Equal Pay Act, as amended by HB 3129

Effective date

January 1, 2025

Employer threshold

15 or more employees

Required: pay scale

Yes — wage scale or salary range that is a good-faith estimate

Required: benefits

Yes — description of benefits associated with the role

Internal posting requirement

Yes — open roles must be announced to existing Illinois employees

Penalty

$500-$10,000 per violation

Enforced by

Illinois Department of Labor

What the pay scale requirement means

Illinois requires a “pay scale and benefits” disclosure — not just a salary range. The pay scale must be a good-faith estimate of the compensation for the role based on the employer’s pay scale for existing employees in the same or similar roles, or the budgeted amount for the role if no similar position exists.

A single salary figure does not satisfy the requirement. Neither does vague language. The disclosure must be a meaningful minimum-to-maximum range that gives applicants useful information about likely compensation.

The benefits requirement

Illinois joins Colorado, Washington, Delaware, Maryland, and Minnesota in requiring a benefits description alongside the salary range. The posting must describe the benefits associated with the position. As with other states, this means naming the categories of benefits offered rather than a full detailed breakdown:

• Health, dental, and vision insurance
• Retirement or 401(k) plans
• Life insurance or disability
• Paid time off and sick leave
• Equity, bonuses, or other variable compensation

Generic language like “comprehensive benefits” is not sufficient. Name the actual categories your company offers.

The internal posting requirement

Similar to Colorado, Illinois requires employers to announce open positions to existing Illinois-based employees. The announcement must happen within 14 calendar days of posting the role externally. This requirement applies to all positions, including remote roles, where an Illinois employee could reasonably be considered for the position.

This is frequently the most overlooked part of the Illinois law. Many companies update their external postings but do not have a process for distributing internal announcements on the same timeline.

Penalties

The Illinois Department of Labor can assess penalties of $500 to $10,000 per violation. Unlike some states, Illinois does not provide a mandatory cure period — violations can be penalized from the first offense. Penalties can accumulate quickly for companies with many open roles, particularly those with postings in Illinois or remote-US postings that are accessible to Illinois applicants.