Resources and Guidance for Preparing to Submit a Minimum Equity Standard (MES) Year-End Report

With the close of the current Program Year on May 30, 2025, the Program is providing guidance to participating entities on completing their required MES Year-End Report. This email contains details on key dates and deadlines, items that can be prepared in advance of the deadline, consequences for failing to meet the MES or alternatively, for the process to request a waiver from required MES compliance.

For the Illinois Shines 2024-25 Program Year, each participating Approved Vendor and Designee must meet a required minimum percentage of 10% Equity Eligible Persons (“EEPs”) in their project workforce. With the exception of Equity Eligible Contractors (“EECs”), all Approved Vendors and Designees participating in the Illinois Shines program must comply with this requirement. The purpose of the MES is to ensure increased access to employment in the Illinois clean energy sector for those who historically have been excluded from such opportunities. More information about the Minimum Equity Standard is available at https://illinoisshines.com/minimum-equity-standard/, including the Guide to the Equity Accountability System & Illinois Shines and the Equity Accountability System Assessment.

Below are Key Dates for MES compliance:

• April 2025 – MES Compliance Plan for next Program Year (2025-26) opens for submissions
• May 2025 – Program Year 2024-25 MES Year-End Report opens for submissions
• May 30, 2025 – Conclusion of the 2024-25 Program Year
• June 2, 2025 – Submission deadline for Program Year 2025-26 MES Compliance Plan
• July 15, 2025 – Submission deadline for Program Year 2024-25 MES Year-End Report
• July 15, 2025 – Submission deadline for Program Year 2024-25 MES Waiver
  
  

MES Year-End Report Submission Requirements
The MES Year-End Report is intended for your organization to document compliance with the MES across a Program Year. A template for the MES Year-End Report can be viewed on the Program website here, or in Appendix S of the Program Guidebook. The submission form for MES Year-End Reports will be made available in May 2025. Program participants will be notified of the availability of the MES Year-End Report via email from the Program Administrator. The MES Year-End Report will require the following data and information:

• Approved Vendor and Designee information
• Project workforce total
• Project workforce demographic information
• EEP workforce totals and demographic information, including proof of EEP eligibility and any supporting documentation for any EEPs not registered in the IPA’s Energy Workforce Equity Portal (e.g., for individuals that qualify based on residency in an Equity Investment Eligible Community [“EIEC”] or through participation in a qualifying training program, submission of proof will be required)
• Description of outreach efforts employed by the Approved Vendor or Designee to recruit EEPs
• Job training program graduate hiring data, Illinois-based workforce diversity data
• Other data previously collected during the Approved Vendor Annual Report
  
  

Preparation Steps for Year-End Report Submission
Approved Vendors 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, Approved Vendors/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, this might provide an easier route to compliance with the MES. If your organization’s EEPs are NOT registered in the Energy Workforce Equity Portal, your organization will be required to collect signed EEP attestations and to provide documentation for those individuals’ EEP qualifications to submit to the Program Administrator. The Energy Workforce Equity Portal can be accessed here: https://energyequity.illinois.gov/.

Additional steps to take in preparing the Year-End Report include requesting project workforce data from subcontractors and confirming your 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.

Safe Harbor Approach for MES Compliance
Regarding the applicability of the Minimum Equity Standard to businesses that have a small number of Illinois-based employees working on Illinois Shines projects such that the Minimum Equity Standard (MES) calculation results in less than one employee, the Agency offers the following guidance:

Application of the MES to Businesses with Small Workforce Totals

In the 2024-2025 Program Year, the Minimum Equity Standard (“MES”) requires that at least 10% of an entity’s Illinois-based Illinois Shines project workforce be comprised of Equity Eligible Persons or Equity Eligible Contractors. 

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.  The following table shows the schedule and percentages of required EEP project workforce composition for businesses with small workforce totals.

Please note: the MES compliance rate will increase to 14% in PY 25-26 at which time any entity with eight or more employees must have at least one EEP in its workforce to be considered compliant. 

*The above schedule was proposed by the Agency and approved by the ICC in 2024. The Agency may propose changes to this schedule based on market trends in the future, which would be subject to approval by the ICC.

Small Business Safe Harbor Approach
Only companies that meet all of the following criteria are eligible for 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 by following this approach. The required Safe Harbor activities are outlined further below. 

For Program Year 2024-25, this approach applies to entities that:

• Have fewer than 10 employees, and
• Hired new staff during the 2024-25 Program Year, and
• Did not hire an Equity Eligible Person (“EEP”) and do not otherwise meet the Minimum Equity Standard (“MES”) by having an EEP on staff.
  
  

Demonstration of Eligibility for Safe Harbor:
To demonstrate a good faith effort to comply with the Minimum Equity Standard, entities must complete at least two activities from the list below (from any of the five categories; they do not need to be from the same category). These activities are designed to ensure meaningful efforts are made to recruit and hire EEPs or engage EECs.

1. Active Utilization of the Energy Workforce Equity Portal
   • Register your organization as an employer on the Energy Workforce Equity Portal and, for any hiring done during the Program Year, post job opportunities to the Equity Portal.
   • Conduct direct correspondence with EEPs who are seeking work in the sector, raising awareness to job opportunities within your organization.
   • Conduct direct outreach to EECs listed on the Equity Portal to explore meaningful partnerships and subcontracting opportunities.
2. Engagement with Regional Workforce Development and Community-Based Organizations in Recruitment Efforts
   • Participate in at least one job fair (virtual or in-person) that is specifically focused on or located in an Equity Investment Eligible Community (“EIEC”).
   • Demonstrate how the entity developed relationships with regional workforce development, community-based organizations or community colleges to advertise job opportunities and recruit EEPs.
   • Advertise employment opportunities with community-based organizations or economic development organizations working with individuals residing in EIEC areas.
3. Conduct Outreach to Job Training Program Equity-Focused Groups
   • Collaborate with qualifying job training programs, such as those supporting formerly incarcerated individuals or foster care graduates, to identify and recruit eligible candidates.
4. Post Job Opportunities on State-Sponsored Platforms
   • Publicize employment opportunities on platforms such as Illinois Job Link or Illinois WorkNet to reach a broader audience of potential candidates.
5. Collaborate with the Program Administrator
   • Meet with the Illinois Shines Program Administrator to review your hiring plans and receive feedback on recruitment strategies aimed at engaging EEPs or EECs effectively.
   •  Attend a webinar conducted by the Illinois Shines Program Administrator on MES-related topics.
     
     

Good Faith Compliance Documentation
To demonstrate good faith efforts, entities are required to maintain and furnish records of their recruitment and outreach efforts, including items such as:

• Copies of outreach communications with EEPs or EECs.
• Copies of job postings on state-sponsored platforms.
• Evidence of participation in job fairs or community events.
• Communication logs or collaboration agreements with workforce development programs, community-based organizations, unions, etc.
  
  

This documentation must be submitted with the entity’s MES Year-End Report. Failure to perform at least two activities during the relevant Program Year or to submit associated documentation will result in a finding of non-compliance with the Minimum Equity Standard.  Absent a waiver or demonstration of compliance through having an EEP in its Illinois-based Illinois Shines project workforce, entities are deemed non-compliant with the MES requirement and be suspended from the Illinois Shines program. Entities are encouraged to proactively seek guidance from the Program Administrator to ensure they remain eligible for Small Business Safe Harbor of the MES requirement.

MES Waiver
If, despite significant and well-documented efforts, your organization determines that prior to June 1, 2025, it will not achieve the 10% MES goal for Program Year 2024-25, your organization can request a waiver. In order to qualify for a waiver, your organization must demonstrate the outreach activities and efforts it conducted to connect with and attempt to recruit EEPs, and to detail why those efforts were not successful, ultimately resulting in noncompliance with the MES.

Waiver requests are evaluated against a scoring system, with each waiver item scored, and a minimum score of 20 points needed to grant a waiver. The template for the waiver request can be found here in Appendix J of the Program Guidebook.

Consequences of Non-Compliance
If the Approved Vendor/Designee has not met the MES for the Program Year, the Approved Vendor/Designee will be suspended and unable to continue participating in the Program. The Approved Vendor/Designee may be required to enter into a Corrective Action Plan to achieve compliance. An Approved Vendor/Designee may have their suspension lifted and may participate in the Program once they have achieved the requirements in their Corrective Action Plan.

MES Webinar Recording
The Program Administrator held a webinar about upcoming MES reporting requirements on Tuesday, April 15^th. The recording of the webinar can be reviewed here: https://www.youtube.com/watch?v=mkfwdS911Hg&feature=youtu.be.  

Next Steps

• The Program Administrator will be opening the MES Compliance Plan form for the upcoming Program Year 2025-26 by the end of April. Participating entities will receive an email from the Program Administrator with a link to their secure submission form. All MES Compliance Plans are due on June 2. 
• Similarly, the MES Year-End Report form for the 2024-25 Program Year will open for submissions in May. You will receive an email from the Program Administrator with more information. In the meantime, please use the guidance above to prepare for your submission. All MES Year-End Reports will be due on July 15.
• All MES Waivers for the 2024-25 Program Year will be due on July 15.
• Additional resources on the MES and the Equity Accountability System can be found here: https://illinoisshines.com/equity-accountability-system-hub/
  • For any questions related to the MES Year-End Report, please reach out to [email protected].
    
    

Thank you!    
Illinois Shines Program    
[email protected]