SB3601
PROFESSIONAL AI OVERSIGHT ACT
TL;DR
Illinois Senator Steve Stadelman's SB3601 would require any professional licensed by the Illinois Department of Financial and Professional Regulation (think real estate agents, accountants, cosmetologists, contractors) to tell paying clients when they're interacting with AI instead of a human, both verbally and in writing. It also amends Illinois consumer fraud law so that any business using AI in commerce must disclose that fact if a consumer asks. Violations carry civil penalties up to $2,500 each, starting January 1, 2027.
How This Might Impact Your Business
Any professional licensed by the Illinois Department of Financial and Professional Regulation (real estate, accounting, cosmetology, engineering, contracting, appraisal, and dozens of other regulated fields) must disclose AI use to paying clients, both verbally at the start of calls and in writing before any written exchange.
Disclosures must name the specific purpose of the AI (for example, 'this chatbot is scheduling your appointment' or 'AI is drafting your property valuation'), not just a generic 'we use AI' statement.
Any business selling goods or services in Illinois, regardless of licensing status, commits an unlawful deceptive practice under the Consumer Fraud Act if a customer asks whether they're talking to AI and the business fails to clearly say yes.
Civil penalties reach $2,500 per violation, and each customer interaction could count separately, meaning a chatbot handling thousands of conversations creates significant exposure.
Consumer Fraud Act violations open the door to private lawsuits and Attorney General enforcement, on top of the Department's own penalties.
Licensed mental health and psychology professionals are exempted (they're covered under a separate wellness statute), but most other regulated occupations are in scope.
Effective date is January 1, 2027, giving businesses roughly a year to update scripts, chatbot flows, intake forms, and customer service workflows.
What Should You Do
Inventory every customer touchpoint where AI is used (chatbots, voice agents, automated emails, AI-drafted documents, scheduling assistants) and flag which involve Illinois clients or licensed professionals.
Draft standard AI disclosure language for both verbal and written channels, and have legal review it against the 'specific purpose' requirement before the January 1, 2027 effective date.
Ask your customer service and compliance teams to build a clear 'yes, this is AI' response path for any customer who asks, since a single missed disclosure could trigger Consumer Fraud Act liability.
If you operate in a licensed profession in Illinois, verify with your professional association or counsel whether your license type is covered and monitor the Department of Financial and Professional Regulation for rulemaking updates.
Track SB3601's progress through the Illinois Senate (currently re-referred to Assignments) and watch for companion or amended versions that could expand scope.
Who It Affects
Sponsors
Status Timeline
introduced
Rule 3-9(a) / Re-referred to Assignments
February 5, 2026