Frontier AI · SB 315
AI Safety Measures Act
Artificial Intelligence Safety Measures Act
- Public Act
- PA 104-0538
- Effective
- January 1, 2027
- Enforced by
- Illinois Attorney General; IEMA-OHS under Section 18
- Verified
Sets distinct transparency and incident-reporting duties for frontier developers and additional framework, audit and filing duties for large frontier developers, with staged dates and separate AG and IEMA-OHS mechanisms.
Signed July 6, 2026, the Act distinguishes frontier developers from large frontier developers. The model definition uses more than 10^26 integer or floating-point operations and specified subsequent modifications; large developers also meet the affiliate-group prior-calendar-year revenue threshold above $500 million. Deployment transparency may be published before or concurrently with deployment, and large developers have additional disclosure duties.
The Act begins January 1, 2027, including Section 18’s in-state large-developer filing and fee. The framework duty begins January 1, 2028; annual audits begin then or 90 days after first qualifying, whichever is later. A frontier developer must report a critical safety incident to IEMA-OHS and the Attorney General within 72 hours after learning facts sufficient to establish a reasonable belief that it occurred. The distinct 24-hour imminent-harm disclosure goes to an appropriate authority when the statutory condition is met.
Section 25’s $1 million first-violation and $3 million subsequent-violation penalties name large frontier developers and are recovered exclusively by the Attorney General. Section 18 separately provides an IEMA-OHS filing, fee and notice/hearing mechanism. The Act creates no new private right of action; that is not immunity from duties or remedies under other law. It is enacted but not yet in force as of October 29, 2026.
What it requires
- Large frontier developers must create, publish and at least annually update a frontier AI safety framework beginning January 1, 2028.
- Frontier developers must publish deployment transparency before or concurrently with deployment; large frontier developers have additional disclosure duties.
- Beginning January 1, 2028 or 90 days after first qualifying, whichever is later, large frontier developers must annually retain a third party to audit compliance with Section 10 of the Act.
- Report a critical safety incident to IEMA-OHS and the Attorney General within 72 hours after learning facts sufficient to establish a reasonable belief that it occurred; make the distinct disclosure within 24 hours to an appropriate authority when the statutory imminent-harm condition is met.
- Apply Section 18's in-state large-frontier-developer filing and fee requirements beginning January 1, 2027.
- Maintain the Act's actor-specific employee and whistleblower protections.
Who is covered
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.
What the exposure is
Up to $1M first violation, $3M each after
Section 25 authorizes up to $1 million for a first violation and $3 million for each subsequent violation by a large frontier developer, with recovery exclusively by the Attorney General. Section 18 separately provides an IEMA-OHS filing, fee and notice/hearing mechanism. The Act creates no new private right of action but does not erase duties or remedies under other law.
Key dates
- May 27, 2026 Passed the House 110–0 (Senate 52–5 on May 21)
- June 26, 2026 Sent to the Governor
- July 6, 2026 Signed by Gov. Pritzker as PA 104-0538
- January 1, 2027 Act takes effect
- January 1, 2028 Framework duty begins; annual audit begins then or 90 days after first qualifying, whichever is later
If this applies to you
- 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.
Primary sources 4
- Bill status SB 315 — Bill Status & Full Action History
- Public Act Public Act 104-0538 — Full Text (PDF)
- Public Act PA104-0538 — Actor, duty, date and enforcement clauses (indexed official text) Bounded official indexed clauses independently reviewed October 28, 2026; direct whole-act retrieval remained unavailable. Sections 10, 15, 18, 25, 30 and 99 have distinct actors, clocks and mechanisms.
- Press Gov. Pritzker Signs Nation-Leading Artificial Intelligence Safety Law Signing announcement, July 6, 2026.
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