Illinois · Senate Bill · 104th General Assembly
SB3601
Illinois SB 3601 — Professional AI Oversight Act

Status ● Introduced Effective Jan 1, 2027 Passage Likelihood L

WHAT THIS BILL REGULATES · 1 REQUIREMENT TYPE

How Is This Bill Enforced

Enforcement Authority
Department of Financial and Professional Regulation (DFPR) enforces through administrative proceedings. The Department may investigate any actual, alleged, or suspected violation and assess civil penalties after a hearing under Section 2105-100 of the Civil Administrative Code. Section 25 amends the Consumer Fraud and Deceptive Business Practices Act, making violations of its on-demand disclosure provision enforceable by the Attorney General under existing CFDBPA enforcement mechanisms. No private right of action is created by the Act itself.
Private Right of Action
No private right of action. Enforcement is exclusive to the designated authority.
Penalties
Civil penalty up to $2,500 per violation, assessed by the Department based on the degree of harm and circumstances of the violation. Penalty must be paid within 60 days of the Department's order. The Department's order constitutes a judgment and may be filed and executed in the same manner as any judgment from a court of record. Violations of Section 2MMMM (CFDBPA amendment) are subject to the existing remedies under the Consumer Fraud and Deceptive Business Practices Act, which may include injunctive relief and AG-sought penalties.

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 Professional AI Oversight Act.

Establishes the short title of the Act as the Professional AI Oversight Act. No substantive obligations are imposed.

Section 5
Definitions

As used in this Act: "Artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act. "DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5" means the Department of Financial and Professional Regulation. "LicenseLicense"License" has the meaning given to that term in Section 2105-5 of the Civil Administrative Code of Illinois.Section 5" has the meaning given to that term in Section 2105-5 of the Civil Administrative Code of Illinois. "LicenseeLicensee"Licensee" means any person licensed in a regulated occupation by the Department.Section 5" means any person licensed in a regulated occupationRegulated occupation"Regulated occupation" means an occupation regulated by the Department that requires a person to obtain a license or State certification to practice the occupation. "Regulated occupation" does not include occupations held by licensed professionals, as defined in Section 10 of the Wellness and Oversight for Psychological Resources Act, or occupations exempted under Section 35 of the Wellness and Oversight for Psychological Resources Act.Section 5 by the DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5. "Regulated occupationRegulated occupation"Regulated occupation" means an occupation regulated by the Department that requires a person to obtain a license or State certification to practice the occupation. "Regulated occupation" does not include occupations held by licensed professionals, as defined in Section 10 of the Wellness and Oversight for Psychological Resources Act, or occupations exempted under Section 35 of the Wellness and Oversight for Psychological Resources Act.Section 5" means an occupation regulated by the DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5 that requires a person to obtain a licenseLicense"License" has the meaning given to that term in Section 2105-5 of the Civil Administrative Code of Illinois.Section 5 or State certificationState certification"State certification" means a State-granted authorization given to a person to use the word "State-certified" as part of a designated title for a specified occupation: (1) based on the person meeting personal qualifications established under State law; and (2) where State law prohibits a noncertified person from using the word "State-certified" as part of a designated title for a specified occupation but does not otherwise prohibit a noncertified person from engaging in the specified occupation for compensation.Section 5 to practice the occupation. "Regulated occupationRegulated occupation"Regulated occupation" means an occupation regulated by the Department that requires a person to obtain a license or State certification to practice the occupation. "Regulated occupation" does not include occupations held by licensed professionals, as defined in Section 10 of the Wellness and Oversight for Psychological Resources Act, or occupations exempted under Section 35 of the Wellness and Oversight for Psychological Resources Act.Section 5" does not include occupations held by licensed professionals, as defined in Section 10 of the Wellness and Oversight for Psychological Resources Act, or occupations exempted under Section 35 of the Wellness and Oversight for Psychological Resources Act. "State certificationState certification"State certification" means a State-granted authorization given to a person to use the word "State-certified" as part of a designated title for a specified occupation: (1) based on the person meeting personal qualifications established under State law; and (2) where State law prohibits a noncertified person from using the word "State-certified" as part of a designated title for a specified occupation but does not otherwise prohibit a noncertified person from engaging in the specified occupation for compensation.Section 5" means a State-granted authorization given to a person to use the word "State-certified" as part of a designated title for a specified occupation: (1) based on the person meeting personal qualifications established under State law; and (2) where State law prohibits a noncertified person from using the word "State-certified" as part of a designated title for a specified occupation but does not otherwise prohibit a noncertified person from engaging in the specified occupation for compensation.

Defines the key terms used throughout the Act: artificial intelligence (by cross-reference to the Illinois Human Rights Act), Department (DFPR), licensee, regulated occupation, and State certification. Notably, regulated occupation carves out occupations covered by the Wellness and Oversight for Psychological Resources Act, meaning mental health professionals subject to that Act are not covered by this bill's proactive disclosure requirements.

Section 10
Use of artificial intelligence disclosure
Professional

(a) 1 A licenseeLicensee"Licensee" means any person licensed in a regulated occupation by the Department.Section 5 shall prominently disclose when a person who is paying for a service provided by the licenseeLicensee"Licensee" means any person licensed in a regulated occupation by the Department.Section 5 is interacting with artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5.

(b)(1)–(2) 1 The disclosure required under this Section shall: (1) be provided (i) verbally at the start of an oral exchange or conversation and (ii) in writing before a written exchange; and (2) notify the person of the specific purpose of the artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 that will be used in the interaction.

(c) Nothing in this Section shall be construed to permit a licenseeLicensee"Licensee" means any person licensed in a regulated occupation by the Department.Section 5 to provide services in a regulated occupationRegulated occupation"Regulated occupation" means an occupation regulated by the Department that requires a person to obtain a license or State certification to practice the occupation. "Regulated occupation" does not include occupations held by licensed professionals, as defined in Section 10 of the Wellness and Oversight for Psychological Resources Act, or occupations exempted under Section 35 of the Wellness and Oversight for Psychological Resources Act.Section 5 through artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 without meeting any other requirements of the regulated occupationRegulated occupation"Regulated occupation" means an occupation regulated by the Department that requires a person to obtain a license or State certification to practice the occupation. "Regulated occupation" does not include occupations held by licensed professionals, as defined in Section 10 of the Wellness and Oversight for Psychological Resources Act, or occupations exempted under Section 35 of the Wellness and Oversight for Psychological Resources Act.Section 5.

Imposes the Act's core proactive disclosure obligation on licensees of regulated occupations. Whenever a paying client is interacting with artificial intelligence, the licensee must prominently disclose that fact — verbally at the start of oral exchanges and in writing before written exchanges — and must specify the purpose of the AI being used. The obligation is unconditional: it does not require the client to ask. Subsection (c) is a savings clause clarifying that disclosure does not authorize licensees to circumvent other regulatory requirements of their occupation.

Compliance actions 1 item
1
LicenseesLicensee"Licensee" means any person licensed in a regulated occupation by the Department.Section 5 must prominently disclose to paying clients that they are interacting with artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 — verbally at the start of oral exchanges and in writing before written exchanges — and must state the specific purpose of the AI being used.
T-01.1
Section 15
Rulemaking

The DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5 shall adopt rules to administer and enforce this Act.

Directs the Department of Financial and Professional Regulation to adopt rules to administer and enforce the Act. This is a standard rulemaking delegation that creates no direct compliance obligation on regulated parties.

Section 20
Enforcement and penalties

(a) Any individual, corporation, or entity found in violation of this Act shall pay a civil penalty to the DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5 in an amount not to exceed $2,500 per violation, as determined by the DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5, with penalties assessed based on the degree of harm and the circumstances of the violation. The civil penalty shall be assessed by the DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5 after a hearing is held in accordance with Section 2105-100 of the Civil Administrative Code of Illinois. An individual, corporation, or entity that is found in violation of this Act shall pay the civil penalty within 60 days after the date of the issuance of an order by the DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5 imposing the civil penalty. The DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5's order shall constitute a judgment and may be filed and executed in the same manner as any judgment from a court of record.

(b) The DepartmentDepartment"Department" means the Department of Financial and Professional Regulation.Section 5 may investigate any actual, alleged, or suspected violation of this Act.

Establishes the enforcement framework for the Act. Civil penalties up to $2,500 per violation may be assessed by the Department after a hearing, with amounts calibrated to the degree of harm and circumstances. Violators must pay within 60 days of the Department's order, which constitutes a judgment enforceable like any court judgment. The Department has authority to investigate actual, alleged, or suspected violations.

815 ILCS 505/2MMMM
Required disclosure of the use of artificial intelligence to engage in trade and commerce
Deployer

(a) As used in this Section, "artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.

(b) 2 It is an unlawful practice within the meaning of this Act for any person to use, prompt, or otherwise cause artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 to interact with a person while engaging in trade and commerce without clearly and conspicuously disclosing to the person with whom the artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 interacts, if asked or prompted by that person, that the person is interacting with artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 and not a human.

Amends the Consumer Fraud and Deceptive Business Practices Act to add a new Section 2MMMM. Makes it an unlawful practice for any person engaged in trade and commerce to use or cause AI to interact with a person without disclosing — when asked or prompted by that person — that the person is interacting with AI rather than a human. This is an on-demand disclosure obligation, distinct from the proactive disclosure required of licensees under Section 10. The trigger is a question from the interacting person, making it narrower in scope but broader in coverage: it applies to any person engaged in trade and commerce, not just DFPR licensees.

Compliance actions 1 item
2
Any person engaged in trade and commerce who uses or causes AI to interact with a person must, when asked or prompted by that person, clearly and conspicuously disclose that the person is interacting with artificial intelligenceArtificial intelligence"Artificial intelligence" has the meaning given to that term in Section 2-101 of the Illinois Human Rights Act.Section 5 and not a human.
T-01.3
Section 97
Severability

The provisions of this Act are severable under Section 1.31 of the Statute on Statutes.

Standard severability provision incorporating Section 1.31 of the Statute on Statutes. No substantive obligations are created.

Section 99
Effective date

This Act takes effect on January 1, 2027.

Sets the effective date for the entire Act as January 1, 2027.

Passage Likelihood

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

Legislative History

2026-02-05 Filed with Secretary by Sen. Steve Stadelman
2026-02-05 First Reading
2026-02-05 Referred to Assignments
2026-02-17 Assigned to Executive
2026-02-18 To AI and Social Media
2026-03-13 Rule 2-10 Committee Deadline Established As March 27, 2026
2026-03-27 Rule 2-10 Committee Deadline Established As April 24, 2026
2026-04-24 Rule 2-10 Committee/3rd Reading Deadline Established As May 15, 2026
2026-05-15 Rule 2-10 Committee/3rd Reading Deadline Established As May 22, 2026
2026-05-22 Rule 3-9(a) / Re-referred to Assignments

Entry Last Reviewed

2026-06-01
AI generated