Enacted laws

Healthcare · HB 1806

WOPR Act

Wellness and Oversight for Psychological Resources Act

In force
Public Act
PA 104-0054
Effective
August 4, 2025
Enforced by
Illinois Department of Financial and Professional Regulation (IDFPR)
Verified

Prohibits AI from acting as an independent therapist, bans emotion detection in clinical settings, and mandates human oversight of AI in mental-health care.

Illinois was the first state to draw a hard line around AI in mental-health care. The WOPR Act makes a distinction the technology had blurred: a licensed human — not a system — delivers therapy. AI may support a clinician’s work, but it may not stand in for one, and it may not claim to read a patient’s emotional state in a clinical setting.

The exposure is concrete. IDFPR enforces the Act with civil penalties of up to $10,000 per violation and, for licensees, the professional-license sanctions that in practice matter more than any fine. Because there is no aggregate cap, a product that violates the Act at scale accrues exposure instance by instance. The Attorney General issued enforcement guidance in early 2026, signalling that this is a statute the state intends to use rather than merely announce.

What it requires

  • Only a licensed professional may deliver mental-health treatment — an AI system may not act as an independent therapist.
  • AI may not be used to detect, infer, or interpret a patient's emotions in a clinical setting.
  • A licensed clinician must retain meaningful human oversight of any AI tool used in the course of care.

Who is covered

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.

What the exposure is

Up to $10,000 civil penalty per violation

Up to $10,000 per violation, enforced by the Illinois Department of Financial and Professional Regulation (IDFPR). Licensed professionals also face license sanctions. There is no aggregate cap, so repeated violations compound.

Key dates

  • January 9, 2025 Filed by Rep. Bob Morgan; referred to Rules
  • August 4, 2025 Signed as PA 104-0054 — effective immediately

If this applies to you

  • 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.

Primary sources 2

  1. Bill status HB 1806 — Bill Status & Full Action History Illinois General Assembly · ilga.gov · retrieved
  2. Public Act Public Act 104-0054 — Full Text (PDF) Illinois General Assembly · ilga.gov · retrieved

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