December 9, 2025
The Illinois Department of Human Rights is considering rules to implement a new notification mandate on employers
The Illinois Department of Human Rights (IDHR) hosted a stakeholder meeting to discuss its draft rulemaking on a new law that requires employers to notify employees when they use artificial intelligence in employment decisions for the purpose of discrimination.
NFIB IL State Director Noah Finley and NFIB IL Leadership Council Chair Cindy Neal of Express Employment Professionals participated in the meeting and shared feedback on IDHR’s draft rulemaking.
The draft rules outline broad new notification and record-keeping requirements for all Illinois employers.
Finley pushed back on a number of clauses, arguing that they didn’t take adequate account of small business owners’ constraints and challenges and that the proposed rules imposed unreasonable burdens on Illinois’ small-business community.
Neal shared her first-hand experiences as an employment professional with the department, outlining real-life factors that the department should consider in its rulemaking.
The proposed rulemaking is to implement Public Act 103-0804, which goes into effect January 1, 2026.
You can read the draft rules here. The underlying legislation can be found here.
If you have feedback on the draft rules—on their clarity, their scope, or their impact on your small business, please contact State Director Noah Finley at noah.finley@nfib.org.
NFIB is a member-driven organization advocating on behalf of small and independent businesses nationwide.
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