Illinois Prevailing Wage Act Updates
There are two recent changes to the Illinois Prevailing Wage Act (“IPWA”) that will significantly impact contractors performing work on IPWA-covered projects.
Apprentice Fringe Benefits Must Match Journeyman Fringe Benefit Rates (Effective June 30, 2025)
Effective June 30, 2025, all apprentices on Illinois prevailing wage projects must receive fringe benefits at the full journeyman level – even if a union collective bargaining agreement (CBA) or apprenticeship program previously allowed a lower fringe rate. In other words, while apprentices can still be paid a lower base wage as they progress, their fringe benefits cannot be below journeyman rates on Illinois public works projects.
If a union agreement sets lower fringe contributions than the prevailing wage requirements, an employer can cover the difference by either contributing extra to the fringe benefit funds or paying the shortfall as wages (additional cash wages can affect overtime calculations).
IPWA Now Covers Certain Federal (Davis-Bacon) Projects (Effective August 14, 2025)
As of August 14, 2025, Illinois expanded the IPWA to include federally funded construction projects administered or controlled by an Illinois public body whenever the Illinois prevailing wage rate equals or exceeds the federal Davis-Bacon rate for the same work in that area. This means that if a state or local agency (IDOT, for example) is overseeing a federally funded project and Illinois’s prevailing wage for a given trade is equal to or higher than the corresponding federal rate, then that work must be paid at the Illinois rate and the project must comply with the IPWA.
In situations where the Illinois prevailing wage is higher than or equal to the federal prevailing wage for some, but not all, of the crafts on a project, whether or not the remaining requirements of the IPWA would apply to just the affected crafts or to the entire project is not clear from the statute
This change is important because Illinois prevailing wage requirements differ from the federal Davis-Bacon rules in several ways. If the IPWA applies to a federal project, contractors face additional state-law obligations – for example, the IPWA covers more workers than Davis-Bacon covers and Illinois may have different overtime (“premium time”) rules and fringe benefit calculations than Davis-Bacon.
IDOL has indicated that it will focus enforcement on new federally funded projects in Illinois bid after August 14, 2025.
© 2025 by Andrew J. Martone and Martone Legal, L.L.C.
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