Illinois Enacts First-in-the-Nation Guardrails On AI Therapy

On August 4, 2025, Illinois enacted the Wellness and Oversight for Psychological Resources Act (HB 1806), the first U.S. state law to specifically regulate the use of artificial intelligence in the professional mental health space. Effective immediately, HB 1806 is designed to protect consumers by tightly circumscribing the permitted versus prohibited uses of AI in the context of "therapy and psychotherapy services."

The law draws a bright line between administrative or supplementary tasks on the one hand, and therapeutic interaction on the other hand. More specifically, licensed therapy professionals may use AI for "administrative support" (e.g., scheduling, billing) and "supplementary support" (e.g., maintaining records, analyzing anonymized clinical data, organizing referrals). However, they are prohibited from letting AI make independent therapeutic decisions, directly interact with clients, generate treatment recommendations without clinician oversight,