When I write a campaign, I see most people will give an EL for every encounter they write. Basically, it would be equal to the encountered creature if that's an encounter with just one creature.
And then I see demons and devils have the abilities called "Summon" that can call their friends to help them out. For example, a Balor can call another Balor once per day, and that called Balor can further call another Balor again, potentially generating an army of infinite Balors if the PCs don't cast things like Dimensional Lock on the battlefield as their first action in the encounter.
In such a case, it seems EL should not be 20 here unless I otherwise rule "this Balor somehow cannot summon anyone". Perhaps it should be "varies" depending on how the fight progresses?