TECHNÉ AI Illinois AI Ecosystem Map
06 / Compliance

From statute to obligation

Each enacted Illinois AI law creates concrete work — policies, notices, audits, training, deadlines. This view maps the statutes to those actions so a compliance lead can move from “what does the law say” to “what do we owe, and by when.” It is a directional map, not legal advice.

In force
9 laws
Effective soon
3 law
Coming if signed
2 bills
01 / In force now

9 statutes you are accountable to today

HB 1806

WOPR Act

In force since August 4, 2025

Applies to Any person or entity that provides mental-health or therapeutic services in Illinois, and the developers of AI tools marketed for clinical or emotional-support use. Licensed clinicians remain personally accountable for care delivered with AI assistance.

Minimum actions
  • AI cannot act as an independent therapist; only licensed humans can deliver mental-health treatment.
  • Disable any emotion-detection or affective-computing features in clinical workflows.
  • Designate a licensed clinician as accountable for every AI-assisted clinical tool you deploy.
  • Document patient consent and clinical-oversight protocols whenever AI is in the loop.
Full analysis & sources
In force since January 1, 2026

Applies to Employers operating in Illinois that use AI or automated decision systems anywhere in the employment lifecycle — sourcing, screening, interviewing, promotion, discipline, or discharge — and the vendors that supply those tools.

Minimum actions
  • Audit every AI hiring or HR tool for disparate impact across protected classes.
  • Notify applicants and employees in writing whenever AI is used in hiring, promotion, discipline, or discharge.
  • Eliminate ZIP codes and other protected-class proxies from AI training and decision inputs.
  • Document your bias-testing methodology and retain results for IDHR review.
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.

Minimum actions
  • Review existing performer, contributor, and likeness contracts for AI-cloning provisions.
  • Re-paper non-compliant likeness contracts with an explicit description of AI-cloning rights and confirmation of counsel or union representation.
  • Add a "no AI cloning without separate written consent" clause to new performer contracts.
  • Maintain a documented record of consent for any AI-generated voice or likeness use.
Full analysis & sources
In force since August 9, 2024

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.

Minimum actions
  • 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 Illinois public school districts and the Illinois State Board of Education. Vendors of classroom AI and curriculum are affected indirectly through district policy.

Minimum actions
  • Adopt or adapt curriculum that teaches students to recognize deepfakes and AI-generated content.
  • Align district and institutional AI-use policies with ISBE guidance as it is published.
  • Train educators on responsible AI use in classroom settings.
  • Document a school-level policy on which AI tools are permitted for student work.
Full analysis & sources
In force since August 9, 2024

Applies to Everyone. This is a universal criminal floor — it applies regardless of industry, size, or use case — with specific operational weight for anyone who builds or operates image-generation tools.

Minimum actions
  • Implement filters that prevent any AI tool from generating sexual imagery of minors (criminal exposure — Class 1 / Class 4 felony).
  • Train staff on recognition and reporting of AI-generated CSAM.
  • Configure customer-facing AI products with abuse-detection guardrails on input and output.
  • Document an incident-response procedure for AI-CSAM discovery, preservation, and law-enforcement reporting.
Full analysis & sources
In force since January 1, 2020

Applies to Illinois employers that use AI to analyze applicant-submitted video interviews, and the vendors that provide the analysis.

Minimum actions
  • Provide written notice to every applicant before AI analyzes their video interview.
  • Explain in plain language how the AI tool works and what it evaluates.
  • Obtain explicit written consent before any AI analysis takes place.
  • Offer applicants the option to opt out and request a human review instead.
Full analysis & sources
In force since August 15, 2025

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.

Minimum actions
  • 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 public school districts and their students. It expands the conduct schools may discipline; it does not create business obligations.

Minimum actions
  • Update district anti-bullying and cyberbullying policies to reference AI-generated images and digital replicas.
  • Brief staff and families on the expanded definitions before the 2026–27 school year.
Full analysis & sources
02 / Effective soon

On the calendar

Effective soon January 1, 2027

Applies to Venue operators, ticket issuers, and resellers offering event tickets to Illinois consumers online — and anyone operating automated purchasing tools against those sales.

Prepare
  • Configure ticketing systems to enforce posted purchase limits against bots and duplicate accounts or email addresses.
  • Publish the count of tickets withheld from public sale at each on-sale.
  • Review reseller and venue agreements for compliance ahead of the January 1, 2027 effective date.
Full analysis & sources
Effective soon January 1, 2027

Applies to "Large frontier developers" — a developer, together with its affiliates, with more than $500 million in gross revenue in the prior calendar year that trains a frontier model using more than 10^26 integer or floating-point operations. In practice this reaches the largest model developers (OpenAI, Anthropic, Google, Meta, xAI); it does not reach startups or academic labs below the revenue and compute thresholds.

Prepare
  • Determine whether your organization crosses the $500M-revenue and 10^26-operation thresholds that define a "large frontier developer."
  • Stand up and publish a frontier AI safety framework, and schedule the annual independent third-party audit.
  • Build a 72-hour (24-hour for imminent-harm) critical-safety-incident reporting pipeline to IEMA and the Attorney General.
  • Put whistleblower protections and internal escalation channels in place ahead of the 2027–2028 phase-in.
Full analysis & sources
Effective soon January 1, 2028

Applies to Health care payors (health insurers and their agents) that adjudicate claims for Illinois clinicians, and the physicians and practices whose claims are subject to downcoding. Home-rule units are barred from separately regulating downcoding of medical claims on or after the effective date.

Full analysis & sources
03 / Coming if signed

The 2 bills sent to the Governor

These passed both chambers and were sent to Gov. Pritzker at spring adjournment. If signed, they take effect January 1, 2027. Organizations they touch should begin preparing now.

SB 316 Sent to Governor

AI Companion Model Safety Act

Companion / character AI chatbots would have to detect when a user expresses suicidal thoughts or self-harm, act to prevent harm, and point the person to a crisis service like the 988 hotline. Passed both chambers; awaiting the Governor's signature.

SB 317 Sent to Governor

Consumer AI Notice Act

If a business uses an AI chatbot to deal with you in commerce, it has to tell you up front that you're talking to an automated system — not a person. Passed both chambers; awaiting the Governor's signature.