A fourth missed shift at a Joliet warehouse
At 2:15 p.m. on the 12th, a shift supervisor at a Joliet distribution center texts the site's HR manager. A forklift operator hurt his wrist loading a trailer, saw a clinic and was told to rest. He has missed his last three scheduled shifts and is not coming in for the fourth.
The HR manager runs injury reporting for three Illinois sites and one in Ohio, alongside payroll questions and benefits enrollment. She keeps a spreadsheet with a tab for each site. It holds dates. It does not hold the rule that says whether this injury has crossed a line, who must hear about it, or by when.
Illinois draws that line by counting scheduled work days, not by the type of injury. By the end of this article you will be able to read the threshold, the filing window and the recipient from the statute, and see which parts of the call belong to you.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
How the Illinois Form 45 employer's first report of injury is triggered
This section reads the rule from the Illinois General Assembly's posting of Public Act 95-0316, which amends Section 6(b) of the Workers' Compensation Act (820 ILCS 305/6(b)). We checked it in 2026. Confirm it against the current compiled statute before you rely on it, because later amendments are possible.
An Illinois employer must report to the Illinois Workers' Compensation Commission each accidental injury that causes the loss of more than 3 scheduled work days, and the report is made between the 15th and 25th of each month (820 ILCS 305/6(b), checked 2026). For an accidental death, the employer must report to the Commission no later than 2 working days after the death (820 ILCS 305/6(b), checked 2026).
| Trigger | Unit | Recipient | Source |
|---|---|---|---|
| Accidental injury causing loss of more than 3 scheduled work days | Report made between the 15th and 25th of each month | Illinois Workers' Compensation Commission | 820 ILCS 305/6(b), checked 2026 |
| Accidental death | No later than 2 working days after the death | Illinois Workers' Compensation Commission | 820 ILCS 305/6(b), checked 2026 |
The statute puts the death rule this way:
"In the case of death such report shall be made no later than 2 working days following the accidental death." — 820 ILCS 305/6(b)
If you searched for the Illinois employer report injury more than 3 days lost time rule, the first sentence above is it. The count is of scheduled work days. The window is a stretch of days within a month. The recipient is the Commission.
The statute text we read does not say which month's injuries each 15th-to-25th window covers. Ask the Commission, and write the answer beside the rule in your tracker.
Form 45 was Illinois's paper first report. The Commission now takes first reports electronically: its FAQ lists "Instructions for EDI submission FROIs/SROIs (formerly Form 45)" under "How does an employer report an accident?", and says Section 6(b) "requires employers (or insurers acting on their behalf) to send reports to the Commission on all accidents involving more than three lost work days", with "first reports on fatal accidents … due within two work days". In practice your insurer or claims administrator often files for you. Confirm how your report reaches the Commission, and the current filing instructions, on the Commission's site.
What you decide, and what the rule leaves to you
The rule counts scheduled work days. That makes your scheduling records, not the calendar, the evidence. How the day of injury and partial days are counted is not something we can state from the text we read, so put that question to the Commission as well.
Work-relatedness and compensability are separate decisions. The statute sets a reporting duty for injuries that meet its threshold. Whether a given injury is compensable is a different question, and the decision is yours, with your carrier.
OSHA runs its own clock. An employer must enter each recordable injury or illness on the OSHA 300 Log and the 301 Incident Report, in the establishment's own records, within seven calendar days of receiving information that a recordable case has occurred (29 CFR 1904.29, checked 2026). Recordability turns on the Part 1904 definitions, not on the Illinois threshold. A case can meet one test and not the other, and you decide recordability.
Our piece on workers' comp claims versus OSHA recordables walks through that difference.
Illinois next to your other states
A first report of injury deadlines chart is only useful if every row carries the same four facts: trigger, unit, recipient and source. Illinois uses scheduled work days and a day-of-month window. Other states use different units and send the report to different places. Here are three rows a multi-state employer might hold side by side:
| State | Trigger | Unit | Recipient | Source |
|---|---|---|---|---|
| Illinois | Injury causing loss of more than 3 scheduled work days | Between the 15th and 25th of each month | Illinois Workers' Compensation Commission | 820 ILCS 305/6(b), checked 2026 |
| Ohio | Injury or occupational disease causing seven days or more of total disability | Within a week after acquiring knowledge | Bureau of Workers' Compensation | ORC §4123.28, checked 2026 |
| Florida | Injury or death | Within 7 days after actual knowledge | Employer's carrier | Fla. Stat. §440.185(2), checked 2026 |
Three states give three triggers, three clocks and three recipients. A spreadsheet can hold the resulting dates. It cannot show which rule produced them or when anyone last checked that rule. A deadline without a citation and a verification date is hard to defend.
For the wider picture, see our guide to workplace injury reporting deadlines by state and the multi-state reporting guide. If the term itself is new, start with first report of injury.
Where tools fit
State agency and carrier portals are the authoritative channels. They are free, but they work one state or one carrier at a time. Spreadsheets and email are familiar and flexible, and many teams have built theirs carefully. They hold dates, not the rule that was in force when a clock started.
The Multi-State First Report of Injury Deadline Tracker is a workbook that computes first-report deadline dates across states from the knowledge date and trigger you enter, and shows the rule each date came from. Check the workbook's state list for Illinois before relying on it. It is a reference tool: you decide recordability and compensability, and you file. It suits a 20-to-100-employee single-state employer as well as a multi-state group, with no subscription needed.
ClaimsIntake is also building an app. It will keep each rule in a versioned table, with a citation and a "last verified" date on every row, and will send escalating alerts to an owner and a backup contact. It is not available yet, and it will not file anything for you. You can join the waitlist.
Three checks before the next Illinois injury
Before the next supervisor text arrives, do three things.
- Read the sources. Read 820 ILCS 305/6(b) and the Commission's instructions for EDI first reports (formerly Form 45), and note the date you checked each.
- Ask the Commission two questions. Which month's injuries does each 15th-to-25th window cover, and how are scheduled work days counted?
- Record the evidence. On every injury record, note the knowledge date and the running count of scheduled work days missed, so the report can be justified later.
Keep the Illinois Form 45 employer's first report of injury in the same file as the OSHA 300 and 301 entries, but treat them as separate decisions with separate clocks.
When you are ready to compute these dates across your states, the deadline tracker workbook is the place to start.
