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Tuesday, March 10, 2026

Illinois L&E Law Changes Effective January 1, 2026 - JD Supra

As we start a new calendar year, Illinois employers need to be aware of several new laws that took effect on January 1, 2026. A PDF version of the “L&E Laws Taking Effect on January 1, 2026” is available here. We will provide a more comprehensive update covering these and other laws that will take effect in 2026 in the near future, however this alert serves as a timely reminder of key changes that may require more immediate attention:

AI Amendments to the Illinois Human Rights Act: Public Act 103-0804 amends the Illinois Human Rights Act (IHRA) by including new obligations on employers to monitor and mitigate the risks of artificial intelligence in employment practices. The amended Act prohibits AI that effectively discriminates against employees on the basis of statuses protected by the IHRA. Additionally, and perhaps most significantly, the amendment also prohibits employer-based AI from using zip codes as a proxy for protected status, such as race or national origin, opening up a new wave of considerations for employers. The zip code restriction requires employers to plan beyond the usual protected status and be very granular about how AI makes decisions. Illinois joins only a few other jurisdictions, including Colorado, Utah, and New York City, who currently regulate the use of AI in the employer context.

Modification of IDHR Investigation Procedures: Public Act 104-0425 amends IHRA to modify investigation procedures and clarify coordination between the Illinois...



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