No, a single-occupancy restroom is not required to have a urinal. The ERA defines a single-occupancy restroom as a room containing one toilet stall and no more than one urinal, but it does not impose a requirement to include a urinal.

A single-occupancy restroom must be identified as an “all-gender” restroom to comply with the ERA, which provides that “every single-occupancy restroom in a place of public accommodation or public building shall be identified as all-gender” and “outfitted with exterior signage that marks the single-occupancy restroom as a restroom and does not indicate any specific gender.”

We also note that the ERA directs the Illinois Department of Public Health to adopt rules to implement this requirement, but the department has not adopted such rules to date. When it does, more detailed information on the required signage may become available.

For resources related to our guidance, please see:

• Equitable Restrooms Act, 410 ILCS 35/25(a) (“‘Single-occupancy restroom’ means a fully enclosed room, with a locking mechanism controlled by the user, containing a sink, toilet stall, and no more than one urinal.”)

• Equitable Restrooms Act, 410 ILCS 35/25(c) (“Notwithstanding any other provision of law, every single-occupancy restroom in a place of public accommodation or public building shall be identified as all-gender and designated for use by no more than one person at a time or for family or assisted use. Each single-occupancy restroom shall be outfitted with exterior signage that marks the single-occupancy restroom as a restroom and does not indicate any specific gender.”)

• Equitable Restrooms Act, 410 ILCS 35/25(e) (“The Department of Public Health shall adopt rules to implement this Section.”)