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ARTICLE · 23 DECEMBER 2025

Illinois Employers Face AI Transparency Deadline Despite New Executive Order

Reinhart, Boerner, Van Deuren SC
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Artificial intelligence (AI) is rapidly becoming embedded in everyday employment decisions—from recruiting and hiring to performance management and discipline...

United StatesTechnology
Michael Gentry
Michael Gentry
Matthew DeLange
Matthew DeLange
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Artificial intelligence (AI) is rapidly becoming embedded in everyday employment decisions—from recruiting and hiring to performance management and discipline—and Illinois is poised to significantly expand employer obligations in this area. Effective Jan. 1, 2026, employers with one or more employees in Illinois (or which are hiring in Illinois) will be required to disclose any use of AI in employment-related decisions under newly enacted Illinois HB 3773. Failure to do so may yield a complaint under the Illinois Human Rights Act. Despite a recent executive order signed by President Trump impacting state AI laws, employers should plan for broad notice, compliance and nondiscrimination requirements to take effect in January.

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