06 / Compliance

From statute to obligation

Selected Illinois AI statutes impose different duties on different actors. This view connects the enacted provisions to practical review steps and upcoming dates, with links to the source text. It is a directional map, not legal advice.

In force
9 laws
Effective soon
3 laws
Law section updated
September 25, 2026
01 / In force now

9 statutes in force as of September 25, 2026

HB 1806

WOPR Act

In force since August 1, 2025

Applies to Individuals and entities providing, advertising, or offering therapy or psychotherapy services to the public in Illinois, including through Internet-based AI, and licensed professionals using AI in that care. A developer is covered when it offers the regulated services.

Review steps
  • Have licensed professionals conduct covered therapy or psychotherapy services.
  • Limit AI used by licensed professionals in those services to permitted administrative or supplementary support; block independent therapeutic decisions, therapeutic client communication, and emotion detection.
  • Make the licensed professional responsible for interactions, outputs, and data use associated with AI-assisted support.
  • When AI assists supplementary support in a recorded or transcribed therapeutic session, provide written notice of its purpose and obtain patient consent.
Full analysis & sources
In force since January 1, 2026

Applies to Employers making covered employment decisions concerning Illinois employees or applicants, including recruitment, hiring, promotion, discipline, and discharge, when they use AI in those decisions.

Review steps
  • Review AI hiring and HR tools for discriminatory effects across protected classes.
  • Provide employees the notice required for covered AI use in employment decisions.
  • Review whether a tool uses ZIP codes as proxies for protected classes in covered decisions and address that risk.
  • Keep records of covered AI use and how potential discriminatory effects were assessed.
Full analysis & sources
In force since August 9, 2024

Applies to Producers, studios, agencies, and platforms in Illinois that contract for the use of a person's voice or likeness — and the performers and creators those contracts bind.

Review steps
  • As a risk-reduction practice, review post-August 9, 2024 personal and professional service agreements for digital-replica provisions that replace new in-person work.
  • As a risk-reduction practice, describe intended replica uses with reasonable specificity.
  • Document either counsel's negotiation of replica rights in written licensing terms or labor-union representation under a collective-bargaining agreement that expressly covers digital-replica uses.
  • For performances fixed from January 1, 2026, check whether asserted consistent uses match both the contract and the fundamental character of the recorded performance.
Full analysis & sources
In force since January 1, 2025

Applies to Anyone who distributes commercial audio or audiovisual content in Illinois — labels, studios, advertisers, platforms — and, as rights-holders, the individuals whose voice or image is replicated.

Review steps
  • Obtain explicit written consent before any AI-generated voice, image, or likeness goes into commercial content.
  • Train marketing and creative teams on the Right of Publicity Act's AI amendments.
  • Document the news, documentary, or satire exception with legal-review sign-off where relied upon.
  • Maintain provenance metadata for every AI-generated talent likeness in production.
Full analysis & sources
In force since January 1, 2026

Applies to The Illinois State Board of Education develops the guidance; school districts can use it when making local AI decisions.

Review steps
  • Consult ISBE's statewide AI guidance when setting local school policies and practices.
  • Distinguish this guidance requirement from any separate statutory district duties.
Full analysis & sources
In force since January 1, 2025

Applies to Persons whose conduct meets the elements of the two criminal offenses under 720 ILCS 5/11-20.4 or 11-23.7.

Review steps
  • Review product safety practices against the elements of both criminal offenses.
  • Train relevant staff to identify and escalate potentially prohibited digitized imagery.
  • Document an incident-response procedure for suspected prohibited material.
Full analysis & sources
In force since January 1, 2020

Applies to Employers considering applicants for positions based in Illinois who ask them to record video interviews and use AI to analyze the recordings.

Review steps
  • Notify applicants and explain the AI analysis before asking them to submit a video interview.
  • Obtain applicant consent before the interview and do not analyze a recording with AI without consent.
  • On an applicant's request, delete their interview within 30 days and instruct recipients to delete their copies.
  • Check whether the separate demographic reporting rule applies when AI analysis alone determines who receives an in-person interview.
Full analysis & sources
In force since January 1, 2026

Applies to Illinois community colleges and their faculty. The limit is on the college's staffing of a course, not on any particular AI product.

Review steps
  • Ensure every course has a qualified faculty member of record as the source of instruction.
  • Position AI tools as faculty-augmentation, and document that framing in course design.
  • Review any fully-automated course offerings against the Public Community College Act.
Full analysis & sources
In force since July 1, 2026

Applies to Illinois school districts, charter schools, non-public non-sectarian elementary and secondary schools, and their students. It expands conduct covered by school anti-bullying rules; it does not create general business obligations.

Review steps
  • Review district anti-bullying and cyberbullying policies for sexually explicit images and unauthorized digital replicas.
  • Charter schools and non-public non-sectarian elementary and secondary schools should also review applicable policies and procedures.
  • Brief staff and families on the expanded definitions for the 2026–27 school year.
Full analysis & sources
02 / Effective soon

On the calendar

Effective soon January 1, 2027

Applies to Any person who creates or uses bots for the prohibited online ticket-purchasing activities. The reporting duty applies to owners or operators of covered event facilities that sell tickets to events, and agents conducting or facilitating those sales; the facility definition has exclusions described below.

Prepare
  • Review purchasing tools and practices for bots that exceed posted limits or bypass online sales-volume controls.
  • Determine whether your venue falls within the event-facility definition and whether you conduct or facilitate its ticket sales.
  • Establish a process for identifying, documenting, and reporting known violations to the Illinois Attorney General within a reasonable period after discovery, including the required report information, ahead of January 1, 2027.
Full analysis & sources
Effective soon January 1, 2027

Applies to Frontier developers, including persons that initiate training of a qualifying frontier model; large frontier developers also satisfy the statutory affiliate-group prior-calendar-year revenue threshold above $500 million. The model definition uses more than 10^26 integer or floating-point operations and specified subsequent modifications. Duties depend on the actor and provision.

Prepare
  • Determine separately whether the organization is a frontier developer and whether it also meets the large-frontier-developer affiliate-group revenue threshold.
  • Plan deployment transparency for publication before or concurrently with deployment, and check the additional large-developer disclosures.
  • For covered in-state large frontier developers, prepare for Section 18 filing and fees beginning January 1, 2027; separately plan the January 1, 2028 framework and conditional annual-audit commencement.
  • Build reporting to IEMA-OHS and the Attorney General within 72 hours after sufficient facts support a reasonable belief that a critical safety incident occurred, with distinct disclosure within 24 hours to an appropriate authority when the statutory imminent-harm condition is met.
  • Review the Act's employee protections and preserve obligations and remedies under other applicable law.
Full analysis & sources
Effective soon January 1, 2028

Applies to Covered health care payors include statutory plan sponsors, issuers and Medicaid managed-care organizations; covered professionals include physicians, physician assistants and advanced practice registered nurses. Apply the January 1, 2028 issue, amendment, delivery or renewal trigger and the exclusions for self-insured ERISA plans, workers' compensation or occupational-disease coverage and excepted benefits.

Full analysis & sources
03 / Proposed legislation

Track proposals separately from obligations

The selected pending bills are in House Rules or Senate Assignments as of the September 23, 2026 status check. A proposal does not create a current legal duty. Review the bill tracker for official status links and proposed requirements.