As the May 31, 2026 close of 2025-26 Program Year approaches, Approved Vendors (AVs) and Designees will need to begin preparing for upcoming Minimum Equity Standard (MES) data and reporting requirements. The IPA and Program Administrator are excited to announce that in response to stakeholder feedback, MES reporting for the prior and next Program Years, previously submitted in two separate reports, will be consolidated into one report due on July 15, 2026. This new combined report, the MES Combined Compliance and Year-End Report, allows entities to simultaneously submit their 2026-27 MES Compliance Plan and their 2025-26 MES Year-End Report. All AVs and Designees participating in the Program are required to submit the MES Combined Compliance and Year-End Report (“Combined Report”).
The Combined Report has two sections:
- The MES Year-End Report looks backward and captures how your organization achieved the MES requirement for the 2025-26 Program Year.
- The MES Compliance Plan is forward-looking and captures how your organization intends to achieve compliance with the MES requirement in the upcoming 2026-27 Program Year.
Please note that for Program Years 2025-26 and 2026-27, the MES requirement is the same: at least 14% of the project workforce for each entity participating in the Illinois Shines program must be composed of Equity Eligible Persons (EEPs). More information about the MES is available on the MES page of the Program website.
This email contains details on key dates and deadlines, an invitation to our upcoming MES webinar, items that can be prepared in advance of the deadline, consequences for failing to meet the MES, and the process to request a waiver from required MES compliance.
Key Dates for MES compliance:
- April 15, 2026 – MES Compliance Webinar (more information below)
- May 2026 – MES Combined Compliance and Year-End Report opens for submissions; program participants will be notified by the Program Administrator via email when the submission form becomes available.
- May 31, 2026 – Conclusion of the 2025-26 Program Year
- July 15, 2026 – Submission deadline for MES Combined Compliance and Year-End Report
- July 15, 2026 – Submission deadline for Program Year 2025-26 MES Waiver Requests
MES Compliance Webinar – April 15, 2026
To ensure compliance and prepare for the upcoming MES reporting season, Illinois Shines AVs and Designees are invited to join the Program’s upcoming MES Compliance Webinar on Wednesday, April 15 at 12:00 p.m. CPT. This webinar will provide guidance on preparing and submitting the MES Combined Compliance and Year-End Report, including information for Equity Eligible Contractors (EECs) who will be required to meet the MES starting in Program Year 2026-27. Register for the webinar here: https://energy-solution.zoom.us/webinar/register/WN_V872nqAiSrWMOEsLXzu4JQ.
MES Year-End Report Submission Requirements
The MES Year-End Report, which appears first in the new combined MES submission, is used to document an organization’s compliance with the MES for the prior Program Year. A template for this year’s MES Year-End Report can be viewed in Appendix Q of the Program Guidebook. The MES Year-End Report portion of the MES Combined Compliance and Year-End Report will request the following data and information:
- Illinois-based project workforce total (as defined in the MES section of the Program Guidebook)
- Illinois-based project workforce demographic information
- EEP total, including proof of EEP eligibility and any supporting documentation
- Outreach efforts employed to recruit EEPs
- Job training program graduate hiring data and Illinois-based workforce diversity data
Preparing for the MES Year-End Report
AVs and Designees are encouraged to begin gathering information needed to complete the MES Year-End Report ahead of time, including encouraging EEPs in their project workforce to register in IPA’s Energy Workforce Equity Portal. In the MES Year-End Report, AVs and Designees will be required to provide the full names of individuals in their project workforce who qualify as EEPs, and the Program Administrator will verify their qualifications as part of the review process. While it is not a requirement to have EEPs register using the Energy Workforce Equity Portal, your organization will be required to collect signed EEP attestations for all EEPs that are NOT registered in the Energy Workforce Equity Portal and to provide documentation for those individuals’ EEP qualifications to submit to the Program Administrator.
In preparation for the Year-End Report, AVs/Designees should also request project workforce data from non-registered subcontractors and confirm their organization’s total Illinois-based Illinois Shines project workforce number. Please keep in mind that Approved Vendors and Designees may contact the Program Administrator for support, including utilizing the Program’s office hours, for any questions that arise during the process.
If your company is unable to meet the MES, there are alternative paths to compliance.
Small Business Safe Harbor Approach for MES Compliance
In the 2025-2026 Program Year, the MES requires that at least 14% of an entity’s Illinois-based Illinois Shines project workforce be comprised of EEPs or EECs. As the MES increases in future Program Years (incrementally to 30% by 2030), participating entities must increase their efforts to attract, recruit, and retain EEPs and EECs into the clean energy workforce.
During the initial years of MES implementation, the IPA sought to clarify how the MES applies to a business with a total Illinois-based project workforce that is small enough that the percentage calculation results in less than one person.
The following table shows the minimum workforce size at which at least one EEP must be employed to meet the MES requirement and how this changes over the next five Program Years.
Please note: the MES compliance rate is 14% for the current, 2025-26 Program Year. Any entity with eight or more employees must have at least one EEP in its workforce to be considered compliant.
| Program Year | Proposed MES Percentage* | Minimum Illinois-based Illinois Shines project workforce at which at least one EEP must be employed to meet the MES requirement |
| PY 25-26 | 14% | 8 or more employees |
| PY 26-27 | 14% | 8 or more employees |
| PY 27-28 | 18% | 6 or more employees |
| PY 28-29 | 22% | 5 or more employees |
| PY 29-30 | 26% | 4 or more employees |
| PY 30-31 | 30% | 4 or more employees |
*The above schedule was proposed by the Agency and approved by the ICC in 2026. The Agency may propose changes to this schedule based on market trends in the future, which would be subject to approval by the ICC.
Only companies that meet all the following criteria are eligible to meet the MES Requirement via the Safe Harbor Approach. These entities will be considered compliant with the MES requirement if they can demonstrate a good faith effort to comply with the MES. The required Safe Harbor activities are outlined in the guidance document, including demonstration of eligibility for Safe Harbor, and good faith compliance documentation that must be submitted with the entity’s Year-End Report
For Program Year 2025-26, this approach applies to entities that:
- Have fewer than 8 employees, and
- Hired new staff during the 2024-25 Program Year, and
- Did not hire an EEP and do not otherwise meet the MES by having an EEP on staff.
MES Waiver
If, despite significant and well-documented efforts, your organization determines that prior to June 1, 2026, it will not achieve the 14% MES goal for Program Year 2025-26, your organization can request an MES waiver. To qualify for a waiver, an organization must demonstrate that it undertook significant efforts to connect with and recruit EEPs, and detail why those efforts were not successful, resulting in noncompliance with the MES.
Waiver requests are evaluated against a scoring system, with a minimum score of 20 points needed to grant a waiver (or 16 points for entities that do not work with subcontractors). The template for the MES waiver can be found in Appendix J of the Program Guidebook.
Consequences of Non-Compliance
If the AV or Designee has not met the MES for the Program Year, or has failed to comply with reporting requirements, the AV or Designee will be suspended and unable to continue participating in the Program. The AV or Designee may be required to enter into a Corrective Action Plan to achieve compliance. An AV or Designee may have their suspension lifted and may participate in the Program once they have achieved the requirements in their Corrective Action Plan.
Next Steps
- Register for and attend the April 15, 2026, MES Compliance webinar.
- Gather all project workforce data and documentation for the MES Combined Compliance and Year-End Report:
- The Program Administrator will open the MES Combined Compliance and Year-End Report submission form by the end of May. Participating entities will receive an email from the Program Administrator with a link to their secure submission form. All Reports are due on July 15.
- If your organization is considering requesting an MES Waiver for the 2025-26 Program Year, please note that an MES Combined Compliance and Year-End Report is still required. MES Waiver Requests are also due on July 15.
- Additional resources on the MES and the Equity Accountability System can be found on the Equity Accountability System page of the Program website.
- For any questions related to the MES Combined Compliance and Year-End Report, please reach out to [email protected].
Thank you!
Illinois Shines Program
[email protected]