EffectiveHB 3773

Illinois HB 3773 (AI in Employment Decisions): Compliance Checklist

A practical checklist of the main obligations to satisfy under this law.

Compliance checklist

Run through these items to scope your obligations under Illinois HB 3773 (AI in Employment Decisions). Not legal advice; verify with counsel before acting.

  1. Confirm scope: does the law apply to your operations? See Who Must Comply or use the Compliance Checker.
  2. Inventory in-scope AI systems and classify them by role (developer/deployer) and decision type.
  3. Address each obligation:
    • governanceRefrain from using AI that has the effect of subjecting employees or applicants to discrimination on the basis of protected classes under the Illinois Human Rights Act in employment decisions.775 ILCS 5/2-102(L)
    • disclosureProvide notice to employees and applicants when AI is being used to make employment-related decisions covered by the amended IHRA.775 ILCS 5/2-102(L)
  4. Adopt a federal control framework: NIST AI RMF or ISO/IEC 42001 to demonstrate due care.
  5. Document evidence of compliance for each obligation, refreshed at the cadence the law requires.
  6. Build the AG-notification path if the law requires it (Colorado, California SB 53).
  7. Set the refresh cadence — annual for most impact-assessment regimes; continuous for monitoring.
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