Illinois · House Bill · 104th General Assembly (2025-2026)
HB4987
Illinois HB 4987 — Surveillance-Based Wage Discrimination Act

Status ● Introduced Effective N/A Passage Likelihood L

How Is This Bill Enforced

Enforcement Authority
Dual enforcement. The Illinois Attorney General is designated to enforce the Act. The Act also creates a private right of action allowing aggrieved persons to bring civil suits individually or on behalf of similarly situated persons.
Private Right of Action
private right of action allowing aggrieved persons to bring civil suits individually or on behalf of similarly situated persons.
Penalties
Attorney General may seek civil penalties not to exceed $10,000 per violation plus reasonable attorney's fees. Private plaintiffs may recover the greater of (1) actual damages, (2) $3,000 per violation, or (3) treble actual damages on clear and convincing evidence of bad faith or intentional violation, plus costs and reasonable attorney's fees, and may seek injunctive relief. Each affected employee constitutes a separate violation.

What This Bill Requires

Verbatim statutory text on the left; plain-language analysis and a per-section checklist on the right. Numbered markers cross-link to the matching checklist row.

Statutory Text
Analysis & Obligations
Section 1
Short title

This Act may be cited as the Surveillance-Based Wage Discrimination Act.

Establishes the short title of the Act as the Surveillance-Based Wage Discrimination Act. Imposes no substantive obligation.

Section 5
Definitions

As used in this Act: "Automated decision systemAutomated decision system"Automated decision system" means any system, software, or process, including one derived from machine learning, statistics, or other data processing or artificial intelligence techniques and excluding passive computing infrastructure, that uses computation, the result of which is used to assist or replace human decision-making.Section 5" means any system, software, or process, including one derived from machine learning, statistics, or other data processing or artificial intelligence techniques and excluding passive computing infrastructure, that uses computation, the result of which is used to assist or replace human decision-making. "BehaviorsBehaviors"Behaviors" mean an individual's observable, measurable, or inferred actions, habits, preferences, interests, or vulnerabilities, including an individual's political, personal, or professional affiliations, web browsing history, purchase history, financial circumstances, or consumer behaviors.Section 5" mean an individual's observable, measurable, or inferred actions, habits, preferences, interests, or vulnerabilities, including an individual's political, personal, or professional affiliations, web browsing history, purchase history, financial circumstances, or consumer behaviorsBehaviors"Behaviors" mean an individual's observable, measurable, or inferred actions, habits, preferences, interests, or vulnerabilities, including an individual's political, personal, or professional affiliations, web browsing history, purchase history, financial circumstances, or consumer behaviors.Section 5. "Biometric informationBiometric information"Biometric information" means data or information generated by the technological, processing, measurement, or analysis of an employee's biological, physical, or behavioral characteristics, that can be used for the purpose of uniquely identifying an individual. "Biometric information" includes fingerprints, voiceprints, scans or records of an eye retina or iris, facial maps, facial geometry, facial templates, genetic information, or other unique biological, physical, or behavioral patterns or characteristics.Section 5" means data or information generated by the technological, processing, measurement, or analysis of an employee's biological, physical, or behavioral characteristics, that can be used for the purpose of uniquely identifying an individual. "Biometric informationBiometric information"Biometric information" means data or information generated by the technological, processing, measurement, or analysis of an employee's biological, physical, or behavioral characteristics, that can be used for the purpose of uniquely identifying an individual. "Biometric information" includes fingerprints, voiceprints, scans or records of an eye retina or iris, facial maps, facial geometry, facial templates, genetic information, or other unique biological, physical, or behavioral patterns or characteristics.Section 5" includes fingerprints, voiceprints, scans or records of an eye retina or iris, facial maps, facial geometry, facial templates, genetic information, or other unique biological, physical, or behavioral patterns or characteristics. "Employee" has the meaning set forth in the Illinois Wage Payment and Collection Act. "Genetic information" has the meaning set forth in the Health Insurance Portability and Accountability Act of 1996, as specified in 45 CFR 160.103. "IndividualizedIndividualized"Individualized" means specific to an individual or group, band, class, or tier of individuals with particular personal characteristics, behaviors, or biometric information.Section 5" means specific to an individual or group, band, class, or tier of individuals with particular personal characteristicsPersonal characteristics"Personal characteristics" means individual qualities, features, attributes, or traits, including immutable characteristics, such as race and eye color, mutable characteristics, such as address, weight, citizenship, or parenthood status, and any other personally identifiable information that could be used to identify an individual, including social security number, name, or phone number.Section 5, behaviorsBehaviors"Behaviors" mean an individual's observable, measurable, or inferred actions, habits, preferences, interests, or vulnerabilities, including an individual's political, personal, or professional affiliations, web browsing history, purchase history, financial circumstances, or consumer behaviors.Section 5, or biometric informationBiometric information"Biometric information" means data or information generated by the technological, processing, measurement, or analysis of an employee's biological, physical, or behavioral characteristics, that can be used for the purpose of uniquely identifying an individual. "Biometric information" includes fingerprints, voiceprints, scans or records of an eye retina or iris, facial maps, facial geometry, facial templates, genetic information, or other unique biological, physical, or behavioral patterns or characteristics.Section 5. "Personal characteristicsPersonal characteristics"Personal characteristics" means individual qualities, features, attributes, or traits, including immutable characteristics, such as race and eye color, mutable characteristics, such as address, weight, citizenship, or parenthood status, and any other personally identifiable information that could be used to identify an individual, including social security number, name, or phone number.Section 5" means individual qualities, features, attributes, or traits, including immutable characteristics, such as race and eye color, mutable characteristics, such as address, weight, citizenship, or parenthood status, and any other personally identifiable information that could be used to identify an individual, including social security number, name, or phone number. "Surveillance dataSurveillance data"Surveillance data" means data obtained through observation, inference, or surveillance of an employee that is related to personal characteristics, behaviors, or biometric information of the individual or group, band, class, or tier of individuals of which the individual is a part. "Surveillance data" includes information gathered, purchased, or otherwise acquired.Section 5" means data obtained through observation, inference, or surveillance of an employee that is related to personal characteristicsPersonal characteristics"Personal characteristics" means individual qualities, features, attributes, or traits, including immutable characteristics, such as race and eye color, mutable characteristics, such as address, weight, citizenship, or parenthood status, and any other personally identifiable information that could be used to identify an individual, including social security number, name, or phone number.Section 5, behaviorsBehaviors"Behaviors" mean an individual's observable, measurable, or inferred actions, habits, preferences, interests, or vulnerabilities, including an individual's political, personal, or professional affiliations, web browsing history, purchase history, financial circumstances, or consumer behaviors.Section 5, or biometric information of the individual or group, band, class, or tier of individuals of which the individual is a part. "Surveillance dataSurveillance data"Surveillance data" means data obtained through observation, inference, or surveillance of an employee that is related to personal characteristics, behaviors, or biometric information of the individual or group, band, class, or tier of individuals of which the individual is a part. "Surveillance data" includes information gathered, purchased, or otherwise acquired.Section 5" includes information gathered, purchased, or otherwise acquired. "Wage" has the meaning set forth in the Illinois Wage Payment and Collection Act.

Defines the operative terms of the Act. Notably, Automated decision system is defined broadly to encompass any computational system used to assist or replace human decision-making, including machine learning and statistical systems, but excluding passive infrastructure. Surveillance data sweeps in any data obtained through observation, inference, or surveillance of an employee — including data that is purchased from third parties — that relates to personal characteristics, behaviors, or biometric information.

Definitions of Employee and Wage are imported by reference from the Illinois Wage Payment and Collection Act.

Section 10
Prohibit surveillance-based wage discrimination
Deployer

(a) 1 A person shall not use surveillance dataSurveillance data"Surveillance data" means data obtained through observation, inference, or surveillance of an employee that is related to personal characteristics, behaviors, or biometric information of the individual or group, band, class, or tier of individuals of which the individual is a part. "Surveillance data" includes information gathered, purchased, or otherwise acquired.Section 5 as part of an automated decision systemAutomated decision system"Automated decision system" means any system, software, or process, including one derived from machine learning, statistics, or other data processing or artificial intelligence techniques and excluding passive computing infrastructure, that uses computation, the result of which is used to assist or replace human decision-making.Section 5 to inform the individualizedIndividualized"Individualized" means specific to an individual or group, band, class, or tier of individuals with particular personal characteristics, behaviors, or biometric information.Section 5 wage paid to an employee. A person does not violate this subsection if the person: (1) offered individualizedIndividualized"Individualized" means specific to an individual or group, band, class, or tier of individuals with particular personal characteristics, behaviors, or biometric information.Section 5 wages based solely on: (A) data specific to the individual employee that is directly related to the tasks the employee was hired to perform; or (B) differences in the cost to the employee of providing labor to the person; (2) discloses in plain language before hiring an employee whose wages are set in whole or in part through automated decision-making what data is considered and how automated decision-making considers that data; and (3) developed and proactively provided to employees reasonable procedures to ensure the accuracy of all data considered by an automated decision-making system in setting wage rates, as determined by rule.

(b) This Section shall not apply to a person who makes a decision not to hire an employee that the person has not previously employed.

The operative prohibition. Section 10(a) bars any person from using surveillance data as part of an automated decision system to inform the individualized wage paid to an employee. The provision is structured as a prohibition with a three-part safe harbor: an employer escapes liability only if (i) wages are based solely on task-related individual employee data or actual cost-of-labor differences, (ii) the employer provides plain-language pre-hire disclosure describing what data is considered and how the automated system uses it, AND (iii) the employer has developed and proactively provided employees with reasonable accuracy-assurance procedures, as determined by rule.

Section 10(b) carves out hiring decisions for prospective employees who have not previously been employed by the person — the Act applies only to existing employment relationships.

Compliance actions 1 item
1
Employers must not use surveillance dataSurveillance data"Surveillance data" means data obtained through observation, inference, or surveillance of an employee that is related to personal characteristics, behaviors, or biometric information of the individual or group, band, class, or tier of individuals of which the individual is a part. "Surveillance data" includes information gathered, purchased, or otherwise acquired.Section 5 — observed, inferred, or purchased data about an employee's personal characteristicsPersonal characteristics"Personal characteristics" means individual qualities, features, attributes, or traits, including immutable characteristics, such as race and eye color, mutable characteristics, such as address, weight, citizenship, or parenthood status, and any other personally identifiable information that could be used to identify an individual, including social security number, name, or phone number.Section 5, behaviorsBehaviors"Behaviors" mean an individual's observable, measurable, or inferred actions, habits, preferences, interests, or vulnerabilities, including an individual's political, personal, or professional affiliations, web browsing history, purchase history, financial circumstances, or consumer behaviors.Section 5, or biometrics — as part of any automated decision systemAutomated decision system"Automated decision system" means any system, software, or process, including one derived from machine learning, statistics, or other data processing or artificial intelligence techniques and excluding passive computing infrastructure, that uses computation, the result of which is used to assist or replace human decision-making.Section 5 to set individualizedIndividualized"Individualized" means specific to an individual or group, band, class, or tier of individuals with particular personal characteristics, behaviors, or biometric information.Section 5 wages, unless wages are based solely on task-related employee data or actual cost-of-labor differences, the employer provides plain-language pre-hire disclosure of the data and methodology used, and the employer maintains accuracy procedures for the data.
Section 15
Enforcement

The Attorney General shall enforce this Act. A person who violates this Act shall be subject to a civil penalty not to exceed $10,000 for each violation and reasonable attorney's fees. A violation of any provision of this Act shall constitute a separate violation with respect to each employee.

Designates the Illinois Attorney General as the public enforcer and authorizes civil penalties not to exceed $10,000 per violation plus reasonable attorney's fees. Critically, each affected employee constitutes a separate violation — meaning a single algorithmic wage-setting deployment touching many employees can multiply penalties dramatically.

Section 20
Private right of action

(a)–(b) A person aggrieved by a violation of this Act may bring a civil action on behalf of themselves or a group of similarly situated persons to restrain further violations and to recover damages, costs, and reasonable attorney's fees, including the greater of: (1) the amount of actual damages sustained; (2) $3,000 for each violation; or (3) 3 times the amount of actual damages sustained, if it is established by clear and convincing evidence that the person who violated this Act engaged in bad faith conduct or intentionally violated this Act. (b) A violation of any provision of this Act shall constitute a separate violation with respect to each employee.

Creates a private right of action permitting an aggrieved person to sue individually or on behalf of similarly situated persons (an explicit representative-action authorization). Recoverable amounts are the greater of actual damages, $3,000 per violation, or treble actual damages where bad faith or intentional violation is proven by clear and convincing evidence. Injunctive relief, costs, and reasonable attorney's fees are also available. As with AG enforcement, each affected employee is a separate violation.

Section 25
Relationship with other laws

Nothing in this Act, including the enforcement authority granted to the Attorney General, preempts or otherwise affects any other right, claim, remedy, presumption, or defense available at law or in equity.

Savings clause confirming the Act does not preempt or otherwise affect any other right, claim, remedy, presumption, or defense available at law or in equity. Imposes no compliance obligation.

Section 30
Rulemaking

The Attorney General may adopt rules necessary to implement and enforce this Act.

Authorizes the Attorney General to adopt rules necessary to implement and enforce the Act. The data-accuracy procedures required as a condition of the Section 10 safe harbor are explicitly to be defined by such rule.

Passage Likelihood

Low
Status Introduced
Chamber No passage
Committee No action
Majority party Yes
Bipartisan No
Prior session None

Legislative History

2026-02-04 Filed with the Clerk by Rep. Nabeela Syed
2026-02-06 First Reading
2026-02-06 Referred to Rules Committee
2026-03-18 Assigned to Labor & Commerce Committee
2026-03-27 Rule 19(a) / Re-referred to Rules Committee

Entry Last Reviewed

2026-05-20
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