If your Illinois company has 15 employees or more, you're already covered by a law that most owners your size haven't heard of.
Illinois's pay transparency amendment to the Equal Pay Act took effect January 1, 2025. It's not new anymore, and it's not aimed at big corporations. The threshold is 15 employees, full-time and part-time, counted no matter where in the US they work. A 20-person company isn't close to that line. It's well past it.
This isn't a "someday" compliance item. If you've posted a job in Illinois since the start of 2025 without a pay range on it, you've likely already been out of compliance. Here's what the law actually requires, and what to fix first.
Who has to follow this law
Any employer with 15 or more employees has to comply, and the count isn't limited to Illinois-based staff. If you have a remote team spread across several states, they all count toward your total.
That means a 20-person company with 8 people in Illinois and 12 scattered elsewhere is still covered. Owners who assume this law is "for Illinois employees only" are the ones most likely to get it wrong.
What has to be in a job posting
Every job posting, internal or external, has to include two things:
The pay scale or salary range for the role, or the actual wage if it's fixed.
A general description of the benefits and other compensation (bonuses, commission, stock, anything that isn't base pay).
This applies to a posting on your own careers page, a job board, LinkedIn, or anywhere else you're advertising a role. There's no exception for "we'll just talk about pay once they apply."
What you have to tell applicants before you make an offer
Even if a posting somehow slips through without a pay range, you're still required to disclose the pay scale and benefits to an applicant before you extend an offer. You cannot negotiate your way around disclosure by withholding it until the end.
What you have to do for current employees
If you post a role externally, you have to let your own team know about that same opportunity internally, no later than 14 calendar days after the external posting goes up. Promotional opportunities can't quietly bypass the people already on your payroll.
What you have to keep on file
Pay scale and benefits records for each posting and each position have to be kept for at least five years. If a complaint or audit comes later, "we don't have that anymore" isn't a defense. It's a second problem.
Consider this common pattern: a 20-person Illinois manufacturing company posts an open operations manager role on a job board with no salary listed, the same way they've always done it. An applicant who didn't get the job later asks why the range was never disclosed. The company has no record of what was posted, because nobody kept one. What started as a hiring question is now a compliance question, and the file that would have settled it in five minutes doesn't exist.
Why owners miss this
Most small-business owners assume transparency laws are built for companies with a recruiting department and a formal HR system. Fifteen employees doesn't feel like "big company" territory.
But the law was written around headcount, not org-chart complexity. A 20-person company runs its hiring the same informal way it always has: a quick post, a few interviews, an offer. The law doesn't ask whether you have an HR team. It asks whether you have 15 people.
The fix isn't a new department. It's a habit: decide the range before you write the posting, not after someone asks.
Five questions to check your own postings against
Before your next job posting goes up, run it through this:
Does the posting include a pay range or a fixed wage?
Does it include a general description of benefits and other compensation?
If an applicant asked about pay today, could you point to something you already disclosed, rather than having to figure it out on the spot?
If you posted this role externally, did your current team see it internally within 14 days?
Could you produce the pay scale and benefits info for this posting if someone asked in three years?
If any answer is no, that's your starting point, not a reason to panic.
Where this gets more complicated
This law covers job postings and the moment before an offer. It doesn't require you to publish every employee's current salary, and it doesn't set your pay rates for you. Internal pay equity, how you structure ranges, and how you handle pre-existing roles that haven't been reposted are separate questions worth thinking through on their own.
Multi-state employers should also check whether other states where their remote employees sit have their own, different disclosure rules. Illinois's law is one piece of a bigger, uneven map.
The real question
The question isn't whether this law applies to a company your size. At 15 or more employees, it already does. The question is whether your next job posting would hold up if someone asked you to show your work.
If you're not sure your hiring process would pass that test, start with the free 2-minute Hiring Snapshot. For a full review, the Hiring Decision Check walks through how you're posting roles, evaluating candidates, and documenting the decision, so the gaps show up before an applicant or a regulator finds them.
Want a second set of eyes on one specific posting instead? Request a free consultation and bring it with you.
This article is general information, not legal advice. Employment laws vary by state and situation.
