Illinois labor law, encoded as policies you can deploy.
Illinois has the most layered compliance surface in the Midwest — three minimum wage jurisdictions, ODRISA breaks and day-of-rest, three overlapping paid leave laws, mandatory vacation payout, Chicago Fair Workweek, and a Wage Payment Act that adds 5%-per-month penalties on top of every other remedy. Each rule below runs as a live Teambridge policy with the right enforcement level for the actual stakes.
Last updated: May 4, 202622 policies coveredReviewed against IDOL & Chicago OLS 2026 guidance
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Mandatory Vacation Payout
Illinois treats vacation as earned wages. Auto-includes accrued balance in final pay. Blocks offboarding close without payout.
Block close without vacation payoutSurface PLAWA-vacation comingling risk
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PLAWA Paid Leave — 40 Hours
40 hours of paid leave per 12-month period for any reason — no documentation. Per-paystub balance display. Auto-routes Chicago/Cook County workers to local ordinances.
PLAWA balance on every paystubWarn on retaliation pattern
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Chicago Fair Workweek
14-day advance schedules. Predictability pay for changes. 10-hour rest between shifts. Hours-offered-first to existing workers.
Block schedule under 14-day noticePredictability pay on changes
Compliance, on autopilot.
Every Illinois rule below runs as a live policy in Teambridge. A Chicago shift saved at $15.00/hr is illegal — block at the source. A 14-day-notice schedule for a Chicago covered employer published 10 days out is illegal — same. A vacation-forfeiture-at-termination clause is unenforceable. Each rule gets the right severity, applied automatically, with running 5%-per-month exposure visible against every Wage Payment Act category.
Optimize
Silently routes around the issue.
Flag
Surfaces a note. Action proceeds.
Avoid
Warns and discourages. Allows override.
Critical
Strong warning. Requires acknowledgment.
Block
Hard stop. Cannot proceed.
SofterHarder
The Illinois policy library
22 rules. The right severity for each.
Illinois is the most operationally complex Midwestern state. Three minimum wage jurisdictions overlap (state, Chicago, Cook County). Three paid leave laws overlap (PLAWA, Chicago, Cook County). ODRISA layers meal breaks and day-of-rest on top of FLSA overtime. Chicago Fair Workweek adds 14-day notice and predictability pay for 7 covered industries. The IL Wage Payment Act adds 5%-per-month penalties to every wage-related miss. Teambridge encodes each rule with the right enforcement level for the stakes.
22 Illinois policies, configured by default. Add your own — by client, role, or site — at any time.
01Three-tier minimum wage
Illinois has the most layered minimum-wage structure in the Midwest: $15.00/hr statewide, $16.60+ in Chicago (4+ employees, adjusted annually each July 1 by CPI), and $15.00 in suburban Cook County (with municipal opt-outs). The highest applicable rate is always the controlling floor. Layered on top: a 40% tip credit (much narrower than the federal 70%), Chicago's One Fair Wage Ordinance phasing the tip credit out entirely by 2028, a $13/hr youth wage for under-18 workers in their first 650 hours, and a $14.50/hr training wage for new 18+ workers in their first 90 days.
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State Minimum Wage Floor
$15.00 IL state floor with three-jurisdiction routing. Resolves shift address against Chicago city limits, Cook County boundaries, and municipal opt-out status. Highest applicable rate controls.
Block save below $15.00Route to local rate when higher
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Why per-shift address routing matters
A worker who clocks in Tuesday at a Chicago location earns $16.60+; the same worker clocking in Wednesday at a Cicero location (Cook County, non-opted-out) earns $15.00; clocking in Thursday at a Berwyn location (opted out) defaults to the state $15.00. Per-shift, parcel-level routing is the only reliable way to apply the right rate. Building the rule once at the worker level fails the moment a worker takes shifts across the metro.
The Illinois One Day Rest in Seven Act (820 ILCS 140) covers two distinct rules: a 20-minute meal break for shifts of 7.5+ continuous hours (must begin by hour 5; additional 20-min breaks every 4.5 hours after that), and a 24-hour rest period in every calendar week. The 2023 amendment expanded coverage to all employers regardless of size and increased penalties to $250-$500 per worker per offense for first violations. Workers can voluntarily waive the day of rest for a specific calendar week, but waivers must be in writing, signed, and don't roll over.
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ODRISA Meal Break Enforcement
Auto-inserts a 20-minute meal break in any 7.5+ hour shift, scheduled by hour 5. Adds a second break for shifts of 12+ hours. Blocks publishing without one.
Block publish on 7.5+ hr shift without breakWarn on break scheduled past hour 5
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Day-of-rest tracking is calendar-week, not rolling
ODRISA's day-of-rest rule is calendar-week based — a worker can technically work 12 days in a row if their rest periods land at the boundaries of two calendar weeks. This sounds like a loophole but it's not exploitable in practice: most workforces will fail the rule with normal scheduling unless rest tracking is automatic. Per-worker, per-calendar-week consecutive-day counting is the operational backbone.
Illinois has the most complex paid leave landscape outside the Northeast. The Paid Leave for All Workers Act (PLAWA) covers most of the state with 40 hours of leave for any reason. Chicago has its own ordinance with 40 hours sick + 40 hours paid leave (80 hours total) and mandatory payout for medium and large employers. Cook County has a separate Paid Leave Ordinance with municipal opt-outs. Workers covered by a local ordinance are excluded from PLAWA — which means multi-location operators must track all three and apply the right one per worker, per shift.
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PLAWA Accrual & Usage
Tracks 1 hour per 40 worked accrual (or front-loaded option). Allows usage for any reason without documentation. Routes Chicago and Cook County workers to local ordinances automatically.
Surface PLAWA balance on every paystubWarn manager on retaliation pattern
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No reason required — and that's the operational shift
Traditional sick leave required a covered reason and (often) documentation. PLAWA explicitly bars asking for either. Operators who built workflows around "why is the worker out?" need to reframe: the worker requests the time, the system accrues and tracks, the reason isn't tracked. Retaliation patterns become the watchdog instead of doctor's notes.
Illinois treats accrued vacation as earned wages under the Wage Payment Act (820 ILCS 115/2). If the employer has any vacation or PTO policy, the accrued unused balance must be paid out at termination as part of final compensation. Use-it-or-lose-it provisions that operate AT termination are illegal — a policy saying "unused vacation is forfeited at separation" is unenforceable regardless of how it's worded. This is structurally opposite to Texas (vacation only paid out if policy says so) and matches Colorado's framework. Annual-reset use-it-or-lose-it during employment is legal if workers had reasonable opportunity to use the time.
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Mandatory Vacation Payout
Calculates accrued vacation balance per the employer's written policy and adds it to final pay. Blocks comingling of PLAWA leave into vacation bank (which would convert all PLAWA hours to wages).
Block close without vacation payoutSurface PLAWA-vacation comingling risk
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The PLAWA-vacation comingling trap
Many employers consolidate PLAWA, sick leave, and vacation into a single PTO bank for simplicity. In Illinois that's a costly choice: comingling converts the entire PTO bank into "vacation" under the Wage Payment Act, making the full balance payable at termination. Maintaining separate buckets preserves the PLAWA-leave exclusion from payout. The bookkeeping is more complex; the financial implication is meaningful.
Chicago's Fair Workweek Ordinance (MCC 6-110) is the most operationally complex scheduling rule outside California. Coverage layers three dimensions: industry (Building Services, Healthcare, Hotels, Manufacturing, Restaurants, Retail, Warehouse Services — 7 industries only), employer size (100+ global with 50+ Chicago covered, or 250+/30 locations for restaurants), and worker wage threshold ($32.60/hr or $62,561.90/yr as of July 1, 2025, adjusted annually by CPI). Covered workers get 14 days advance notice, predictability pay for changes inside the window, 10 hours of rest between shifts, and hours-offered-first to existing workers before new hires.
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Chicago Fair Workweek Compliance
Identifies covered employers, industries, and workers. Enforces 14-day notice, predictability pay calculation, 10-hour rest rule, and hours-offered-first workflow.
Block schedule under 14-day noticeCalculate predictability pay on changesWarn on shift gaps under 10 hoursSurface hours-offered-first opportunity
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Manual compliance is essentially impossible
Predictability pay calculations alone — running per-change, per-worker, against the right minimum wage, with the right multiplier (1 hour added/changed vs. 50% of cancelled) — would consume a full FTE for a covered restaurant chain. Add coverage routing (industry × size × wage) and hours-offered-first workflow, and the rule becomes operationally infeasible without enforcement at the source. Chicago has been an active enforcer with $500/worker/offense fines.
The Illinois Worker Adjustment and Retraining Notification Act (820 ILCS 65) is one of the few state WARN-equivalents stricter than federal. Coverage threshold: 75 or more full-time employees in Illinois (federal WARN starts at 100). Triggers: plant closing affecting 25+ workers, mass layoff of 25+ workers if 33%+ of workforce, or 250+ regardless of percentage. 60 days advance written notice required to four recipients: affected employees, Illinois DCEO, the local elected official, and the Illinois Department of Labor. Penalty for non-compliance: back wages and benefits up to 60 days per affected worker, plus civil penalties up to $500/day per violation.
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Illinois WARN Compliance Tracking
Tracks employer coverage at the 75-employee threshold. Identifies events that trigger notice requirements. Surfaces 60-day countdown when triggers approach.
Surface 60-day notice requirementBlock bulk-termination workflow without notice on file
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The 75-99 employee gap is the trap
Multi-state employers with operations both above and below federal WARN's 100-employee threshold often miss IL WARN. An employer with 90 IL employees is below federal but above Illinois — and a 30-person mass layoff there triggers IL WARN obligations the company never planned for. Coverage tracking at the 75-employee mark catches this gap before bulk-termination workflows execute.
The Illinois Wage Payment and Collection Act (820 ILCS 115) is one of the most aggressive state wage statutes in the country. The penalty stack runs: 5% per month penalty on unpaid wages (compounding), mandatory attorney fees on prevailing, double damages for willful violations, plus civil penalties up to $1,000 per violation. Workers can pursue claims through IDOL administratively or in private suit. Class actions are common. Coverage is broad — "wages" under the Act includes regular pay, OT, commissions, bonuses, vacation/PTO, severance per agreement, and expense reimbursements. Statute of limitations: 3 years (10 if willful).
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Wage Claim Exposure Tracking
Surfaces wage compliance gaps before they become claims. Tracks Wage Payment Act exposure across timesheets, deductions, final pay, and overtime. Audit-ready records.
5% per month is the multiplier that builds the case
Most Wage Payment Act cases start small — a single late paycheck of $800, an unauthorized $50 deduction, a $200 vacation forfeiture. The 5%/month accrual makes them grow. A worker who waits 18 months to file is owed the original amount plus 90% in monthly penalties; add attorney fees and double damages for willfulness, and a $1,000 dispute becomes a five-figure liability. Surfacing exposure as it accrues — before workers file — is the only way to stay ahead.
Illinois had one of the busiest legislative cycles in the country, with paid leave enforcement, Chicago's tip credit phase-out, and several new laws taking effect:
Chicago Paid Leave private right of action — through June 30, 2026, a 16-day cure period applies before workers can file private suits. After July 1, 2026, the cure period sunsets and private right of action is immediate. Office of Labor Standards (OLS) accepts complaints throughout.
Chicago One Fair Wage tip credit phase-out — as of July 1, 2025, the maximum tip credit dropped to 24% (cash wage $12.62). Each July 1 from 2026-2028, the credit drops further: 16% (2026, ~$13.94 cash), 8% (2027), 0% (2028). After July 1, 2028, all Chicago tipped workers must receive the full Chicago minimum wage in cash.
Chicago Fair Workweek wage threshold — increased to $32.60/hr or $62,561.90/yr (as of July 1, 2025), adjusted annually each July 1 by CPI. Workers earning at or below the threshold are covered; workers above are not.
Illinois state minimum wage holds at $15.00 — the 2019 multi-year increase schedule reached its target on January 1, 2025. Without further legislation, the rate stays at $15.00 in 2026 with no automatic CPI indexing.
Illinois NICU leave law took effect June 1, 2025, providing protected leave for parents of newborns admitted to a NICU. Operationally separate from PLAWA but interacts with PFML and FMLA.
Illinois Workplace Transparency Act amendments — expanded restrictions on settlement and severance agreements that limit reporting of harassment or discrimination. Affects offboarding workflows and severance template language.
ODRISA penalties — first violations $250-$500 per worker per offense; repeat violations escalate to $1,000+. Active IDOL enforcement throughout 2025 and into 2026, with hospitality, healthcare, and warehousing seeing the most audits.
Frequently asked questions
What is the minimum wage in Illinois in 2026?
$15.00/hr statewide for non-tipped workers 18+. Higher rates apply in Chicago ($16.60+ as of July 1, 2025, adjusted annually each July 1) and parts of Cook County. The highest applicable rate controls. Workers under 18 working under 650 hours per year may be paid $13.00; workers 18+ in their first 90 days may be paid $14.50 training wage.
Does Illinois require paid leave?
Yes — and there are three overlapping laws. The Paid Leave for All Workers Act (PLAWA) provides 40 hours of paid leave per 12-month period for any reason without documentation. The Chicago Paid Leave and Paid Sick and Safe Leave Ordinance provides 40 hours sick + 40 hours paid leave (80 hours total) for Chicago workers. The Cook County Paid Leave Ordinance provides 40 hours for suburban workers in non-opted-out municipalities. Workers covered by a local ordinance are excluded from PLAWA.
Does Illinois require vacation payout at termination?
Yes, if the employer has any vacation or PTO policy. The IL Wage Payment Act treats accrued vacation as earned wages. Use-it-or-lose-it provisions that operate AT termination are illegal — the accrued balance must be paid as part of final compensation regardless of policy text. Annual-reset use-it-or-lose-it during employment is legal if workers had reasonable opportunity to use the time.
What's the Chicago Fair Workweek Ordinance?
A scheduling law covering 7 industries (Building Services, Healthcare, Hotels, Manufacturing, Restaurants, Retail, Warehouse Services) for employers above size thresholds (100+ global with 50+ in Chicago; 250+/30 locations for restaurants). Covered workers earn at or below $32.60/hr. They get 14 days advance notice of schedules, predictability pay for changes, 10 hours of rest between shifts, and hours offered to existing workers before new hires.
When must a final paycheck be issued in Illinois?
At the time of separation if possible, but in no event later than the next regularly scheduled payday. Same deadline applies to voluntary and involuntary terminations. Late final pay incurs a 5% per month penalty under the IL Wage Payment Act, plus mandatory attorney fees, plus double damages for willful violations. Holding the final paycheck because the worker hasn't returned company property is illegal — recover property through other means.
What's the Illinois WARN Act and how is it different from federal?
The Illinois Worker Adjustment and Retraining Notification Act covers employers with 75+ full-time employees in Illinois — stricter than federal WARN's 100+ threshold. Mass layoff trigger is 25+ workers (federal is 50+). 60 days advance written notice is required to four recipients: employees, Illinois DCEO, the local elected official, and the Illinois Department of Labor. Multi-state employers with operations in the 75-99 employee range often miss IL WARN because federal WARN doesn't apply.
What's the rule for wage deductions in Illinois?
820 ILCS 115/9 prohibits any deduction without written, signed authorization given freely at the time of the deduction — except for taxes, court-ordered withholdings, and worker-chosen voluntary benefits. Property losses, breakage, and cash shortages cannot be deducted without prior specific authorization. A handbook clause is not authorization. Property recovery from final pay is the most common Wage Payment Act violation; pursue property through separate workflows, not paychecks.
What's the difference between Critical and Block in Policy Builder?
Block is a hard stop — no override, no exception. Use it for things flat-out illegal (saving a Chicago shift below $16.60, publishing a Fair Workweek covered schedule under 14 days, classifying someone exempt below the $684/week salary basis, deducting without authorization). Critical is a strong warning that requires explicit acknowledgment but allows the action to proceed — use it for things that are operationally normal but compliance-sensitive (a next-payday final pay deadline approaching, a tipped-wage workweek shortfall on payroll close, a 7-consecutive-day pattern emerging under ODRISA).