Federal and state prevailing wage mandates are colliding on construction projects in Illinois, exposing owners, developers, and contractors to conflicting compliance obligations and increased project costs. With the enactment of Illinois HB 1189, projects that long fell exclusively under the federal prevailing wage law (Davis-Bacon) may now also be subject to the state’s prevailing wage law mandates.
While the Illinois Department of Labor (IDOL) has issued guidance for contractors, there is little clarity on how to reconcile fundamental and incompatible differences between state and federal prevailing wage laws. Contractors operating in this environment must understand where these mandates conflict and