Illinois High-Impact AI Governance Principles and Disclosure Act

Applies To

Overview

HB 3529 was filed in the Illinois House on 7 February 2025. It was assigned to the Cybersecurity, Data Analytics and IT Committee, then sent back to the Rules Committee on 21 March 2025 after missing a committee deadline. It has had no action since and is effectively dead for this General Assembly. The bill would direct the Department of Innovation and Technology to adopt rules applying five principles to businesses using AI: safety, transparency, accountability, fairness, and contestability. It applies to all businesses, for-profit or non-profit, with 10 or more employees. It has no sector limits and no separate high-impact tier. Its one disclosure duty is a public report on the business's website, updated annually and after significant changes. The report would cover design decisions, training data, risk mitigation, and any impact assessments conducted, in plain language. A business that fails to comply and disclose compliance faces a $1,000 civil penalty. As introduced, the Act would have taken effect on 1 January 2026. It is separate from SB 315, the Artificial Intelligence Safety Measures Act, which was signed on 6 July 2026 and covers large frontier AI developers.

Key Requirements

• •Applies to businesses, including non-profits, with 10 or more employees using AI in Illinois.
• •Rules would apply five principles: safety, transparency, accountability, fairness, and contestability.
• •Publish a website report on compliance, updated annually and after significant changes.
• •The report covers design decisions, training data, risk mitigation, and any impact assessments conducted.
• •Violations carry a flat $1,000 civil penalty.
• •The bill has stalled in committee since March 2025.

What Your Organization Must Do

• →Track HB 3529's status, since it has stalled in committee and creates no current duty.
• →Confirm whether your Illinois headcount reaches 10 employees, the bill's proposed scope trigger.
• →Map where your business uses AI systems in Illinois, including out-of-state operations serving the state.
• →Draft a plain language public report covering design decisions, training data, and risk mitigation steps.
• →Record any AI impact assessments already completed, since the report would describe them.
• →Brief leadership that exposure, if revived, is a flat $1,000 civil penalty.

Playbook Guidance

Step-by-step implementation guidance for compliance teams.

Frequently Asked Questions

What AI systems would Illinois HB 3529 cover?

Any AI system used by a business with 10 or more employees in Illinois. The bill has no sector list and no separate high-impact category.

Does Illinois HB 3529 apply to businesses headquartered outside Illinois?

It covers businesses using AI systems in Illinois, so out-of-state companies operating there could be in scope. The bill has stalled in committee, so there is no live obligation.

How does Illinois HB 3529 interact with Illinois SB 315?

The two bills are unrelated. SB 315, signed on 6 July 2026, regulates large frontier AI developers. HB 3529 would cover any business with 10 or more employees using AI, and has stalled.

What civil penalty exposure does HB 3529 create?

A flat $1,000 civil penalty for violations, unless the business complies and publicly discloses its compliance.

What would HB 3529 require companies to disclose?

Only a public website report, covering design decisions, training data, risk mitigation, and any impact assessments. There is no individual notice requirement.

Does HB 3529 require impact assessments?

No, the website report must only describe any assessments a business has done. As introduced, the Act would have taken effect on 1 January 2026.