Exempt Timekeeping Requirements
By Kathryn O'Connor, PHR, SHRM-CP, CCP, GRP, Director, Compensation Services
Published July 30, 2024
In Illinois, the requirement for exempt employees to keep time records dates back to 2015 when the Administrative Code of the Wage Payment and Collection Act was updated. This was reinforced in 2019 with an update to Illinois minimum wage law, which added a monetary penalty for non-compliance.
Specifically, Illinois employers must keep true and accurate records of the name, address and occupation of each employee, the rate of pay, the amount paid each pay period to each employee, and the hours worked each day in each work week by each employee. This applies to both exempt and non-exempt employees.
Surprisingly, many Illinois employers don’t know about this requirement or fail to comply with the rule. This article serves as a compliance reminder to ensure all HR Source members and Illinois employers are compliant with the act.
Exempt employee time records don’t need to be as detailed as non-exempt time records. They don’t need to include exact punch times. Providing the total hours worked each day will suffice. At HR Source, we record time in quarter hour increments. An exempt time record may look like this:

The hours recorded each day reflect actual hours worked, not just hours scheduled. The documentation must include time in the office and work performed outside of the office. When work is performed at home or off-site, the time must be added to the timesheet.
Most employers have opted to collect, record, and store the information electronically, though there is no requirement to do so. Keeping paper records is acceptable.
Some employers have also found that it’s easiest to ask exempt employees to use the same time collection method as non-exempt employees. This is also acceptable.
Are you still not convinced exempt time tracking is necessary? It’s important to note these time records play an integral part during wage and hour audits involving employee misclassification. Should a job be misclassified as exempt, these time records will be used to calculate backpay for overtime. Absent these records, the employer may be required to pay backpay based on the employee’s memory or other non-official records, leaving the employer exposed to potential penalties.
HR Source members with questions should contact us through the HR Hotline Online or at 800-448-4584.