HB5003 · Illinois · introduced Feb 4, 2026Introduced

HB5003

AI-ASSISTED THERAPY RESEARCH

Medium RiskMay require changes to AI practices. Monitor and prepare.

TL;DR

Illinois Rep. Bob Morgan's HB5003 carves out a narrow exemption in the state's therapy licensing law so academic medical centers can research AI-assisted therapy without violating rules against unlicensed psychotherapy. The exemption only covers IRB-approved studies at accredited hospitals, not commercial AI therapy products sold to consumers, and it expires January 1, 2030.

How This Might Impact Your Business

Commercial AI therapy and mental health chatbot companies (Woebot, Wysa, Replika-style apps) get no relief here; Illinois still bans consumer-facing AI therapy under the underlying Wellness and Oversight for Psychological Resources Act.

Only academic medical centers affiliated with accredited medical schools, holding Joint Commission accreditation, and running IRB-approved protocols can legally deploy AI therapy tools, and only within research settings.

Existing university research programs must register with the Illinois Department of Financial and Professional Regulation within 90 days of enactment; new programs must register within 30 days of IRB approval and file annual reports.

AI systems used in these studies must be HIPAA-compliant, undergo documented pre-deployment safety testing, include real-time crisis detection, and function only as adjuncts to licensed clinicians (not replacements).

Penalties for passing off a commercial service as 'research' include immediate loss of exemption, civil penalties, licensing board referrals, and a 2-year ban on new exempt programs.

Academic centers cannot advertise AI therapy to the public as routine care or charge participants beyond IRB-approved fees, closing a common workaround.

The entire exemption sunsets January 1, 2030, with a state report due July 1, 2029 that will shape whether AI therapy gets a broader legal path in Illinois.

What Should You Do

1

If you sell AI mental health tools, identify Illinois academic medical center partners (Northwestern, University of Chicago, UIC, Rush) as your only viable channel into the state and structure engagements as research collaborations, not commercial licenses.

2

Have your legal and clinical teams map your AI system against the six qualified-research-program criteria (IRB oversight, HIPAA, safety testing, crisis monitoring, licensed clinician supervision, generalizable-knowledge purpose) before pitching any Illinois partner.

3

Review marketing and sales materials to ensure nothing markets Illinois research deployments as clinical services; misrepresentation triggers civil penalties and a 2-year exemption ban.

4

Track the bill through the Illinois House Rules Committee and flag the July 2029 Department report as a strategic milestone; that report will determine whether the exemption extends past January 2030.

5

Health systems and universities running informal AI therapy pilots should inventory them now and prepare to register within 90 days of enactment or shut them down.

Who It Affects

Healthcare AIDigital Mental HealthAcademic Medical ResearchHealthTech SaaSTelehealthConsumer Wellness Apps

Sponsors

Status Timeline

  1. introduced

    Rule 19(a) / Re-referred to Rules Committee

    February 4, 2026

AI-generated analysis for informational purposes only. Not legal advice. Always consult a qualified attorney for legal guidance.Last action Feb 4, 2026

Need help preparing your team for AI compliance?

Talk to LaunchReady about AI Training

Get the Weekly AI Law Roundup

Plain-English summaries of the AI laws that matter for your business. Every Monday. Free.

No spam. Unsubscribe anytime.