Illinois Regulatory Tracker

Last updated: July 2026

This page tracks Illinois laws affecting commercial facilities that are newly effective in 2025 or 2026. New entries are added quarterly. For a printable version with full member-action recommendations and citations, download the full briefing (PDF).

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• Environmental & Waste
• Labor & Employment
• Safety & Building Codes
• Data Privacy & Consumer Protection
• Recommended Member Actions

At a Glance

Environmental & Waste

Portable & Medium-Format Battery Stewardship Act

Effective January 1, 2026. Producers selling portable and medium-format (4.4–25 lb) batteries into Illinois must join an approved Battery Stewardship Plan. Retailers may not sell batteries from non-participating producers after July 1, 2026. A landfill disposal ban takes effect January 1, 2028.

Member action: Confirm producer enrollment before sale; plan now for the 2028 landfill ban by setting up collection and updating waste-hauler contracts.

PFAS Product Ban (HB 2516)

Effective January 1, 2026. Sale, offer for sale, or distribution of cookware, cosmetics, dental floss, juvenile products, menstrual products, intimate apparel, and food packaging or food-contact products containing intentionally added PFAS is prohibited. Civil penalties: $5,000 (first offense) to $10,000 (repeat). Firefighting clothing bans follow January 1, 2027 (HB 2409).

Member action: Audit private-label SKUs in covered categories; add “no intentionally added PFAS” reps and warranties to supplier contracts.

PFAS Drinking Water MCLs & NPDES Monitoring

Effective January 22, 2026. The Illinois Pollution Control Board adopted MCLs for five PFAS compounds (PFOA, PFOS, PFHxS, PFNA, HFPO-DA). HB 5475 requires major NPDES facilities to include periodic PFAS sampling and bars permits for biosolid land application without PFAS results. Initial monitoring due by April 25, 2027.

PaintCare Paint Stewardship — Live Since December 1, 2025

A 95¢-per-gallon assessment now applies to architectural paint sold in Illinois. Funds 340+ free drop-off sites statewide. Member action: Rebid paint budgets to reflect the pass-through; use PaintCare drop-offs instead of paying for paint as hazardous waste.

Consumer Electronics Recycling Act — Renewal Pending

The current CERA sunsets at the end of 2026. Renewal legislation (SB 2414 / HB 3098) would expand covered devices and open access to small generators like schools and libraries. Watch this space for 2027 obligations.

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Labor & Employment

AI in Employment Decisions (HB 3773)

Effective January 1, 2026. Illinois Human Rights Act amendments require employers to give notice when AI is used in hiring, promotion, or discipline decisions. AI tools may not produce outcomes discriminatory by protected class or ZIP code. Records must be preserved for four years.

Member action: Inventory every vendor or in-house tool that scores, ranks, or evaluates candidates or employees; draft a plain-language AI notice; set a four-year retention rule.

Workplace Transparency Act Amendments

Effective January 1, 2026 (applies to agreements signed, modified, or extended on or after this date). Contract clauses that shorten the statute of limitations, apply non-Illinois law, or require disputes to be resolved outside Illinois are void. Agreements must affirmatively preserve employees' right to participate in unlawful-practices proceedings.

Member action: Pull current offer letter, employment agreement, severance, and arbitration templates; strike non-Illinois choice-of-law and forum clauses.

Paid Lactation Breaks

Effective January 1, 2026. All Illinois employers must provide paid break time for nursing employees to express milk, compensated at the regular rate, not deducted from other leave.

NICU Leave

Effective June 1, 2026. Illinois now requires employers with 16 or more employees to provide unpaid, job-protected leave for a parent while their child is a patient in a neonatal intensive care unit (up to 10 days for employers with 16–50 employees and up to 20 days for employers with more than 50), available regardless of length of service or full- or part-time status. Civil penalties up to $5,000 per infraction.

VESSA & Military Leave Updates

Effective January 1, 2026. VESSA now protects employees who use employer-provided equipment to record crimes of violence against themselves or family. The Military Leave Act now requires employers with 51+ employees to grant up to 8 paid hours per month for funeral honors detail.

Human Rights Act — Penalty Increase

Effective January 1, 2026. Maximum civil penalties for adjudicated employer violations rise to $70,000 for two or more violations within a seven-year window.

Pay Transparency (Live Since January 1, 2025)

Employers with 15+ employees must include pay scale and a general description of benefits in every job posting for positions performed at least in part in Illinois — or reporting to an Illinois supervisor, office, or worksite. Penalties: $500 / $2,500 / $10,000 for first, second, and third-or-subsequent violations. Promotions must be announced internally within 14 days of an external posting, and third-party recruiters must receive the pay range.

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Safety & Building Codes

Statewide Building Code Adoption (Public Act 103-0510)

Effective January 1, 2025 (some jurisdictions phasing in by May 1, 2026). All Illinois municipalities and counties must adopt the IBC for new commercial construction, the IEBC for alterations, and the IRC for residential. Notable updates: three new mass/heavy timber construction types (IV-A, IV-B, IV-C); accessible-egress elevators for buildings 4+ stories with occupied roofs; energy modeling required for buildings over 25,000 sq ft.

Illinois Stretch Energy Code

2023 Stretch Code in effect since January 1, 2025; 2026 update tentative for Q3 2026. Where adopted by a municipality, the Stretch Code applies to privately funded commercial facilities under 20 ILCS 3125. The 2026 update aligns with CEJA targets and increases credit thresholds. Even where not yet adopted, owners pursuing TI work in Chicago and other progressive jurisdictions should plan to it.

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Data Privacy & Consumer Protection

BIPA Amendments (SB 2979)

Signed August 2, 2024; held retroactive by the 7th Circuit (April 2025). The Biometric Information Privacy Act now caps recovery at one violation per person (not per scan), and electronic signatures are valid for consent. The retroactivity ruling lets pending defendants invoke the cap.

Member action: Re-paper biometric consents using e-signature workflows; verify notice, consent, retention, and destruction policies for any timeclock, access-control, or visitor system using fingerprints or facial scans.

AI Disclosure Beyond Employment (Pending — SB 1792)

SB 1792 would amend the Illinois Consumer Fraud and Deceptive Practices Act to require consumer-facing AI operators to disclose that outputs may be inaccurate or inappropriate. Members with customer chatbots, recommendation engines, or generative-AI features should track its progress and prepare disclosure language.

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Recommended Member Actions Before Year-End 2026

• Run an EPR inventory — identify every product covered by a stewardship program (batteries, paint, electronics) or PFAS ban.
• Refresh all employment-document templates to match the 2026 Illinois package, including AI notices.
• Confirm with local building officials when statewide codes apply in your jurisdiction; rerun energy modeling for projects over 25,000 sq ft.
• Re-paper biometric and AI consents using electronic signature; start the four-year AI-disclosure retention clock.
• For multi-state operators, flag Illinois-specific carve-outs in choice-of-law, forum, and limitations clauses across your contract book.

Need the full version with citations? Download the member briefing (PDF).

This page is updated quarterly. Last update: July 2026. Informational only — not legal advice. Members should consult counsel before acting on any specific provision.