SB 3564
POLICE-FACIAL RECOGNITION ACT
TL;DR
Illinois SB 3564, the POLICE-FACIAL RECOGNITION ACT, would regulate how law enforcement agencies in Illinois use facial recognition technology. While aimed at police, it directly affects the vendors that sell facial recognition software and the businesses that share data or video feeds with law enforcement.
How This Might Impact Your Business
Facial recognition vendors selling to Illinois police departments would face new contractual and compliance requirements, likely including accuracy reporting and audit trails.
Retailers, property managers, and venue operators that share security camera footage with police could be pulled into new documentation and disclosure rules.
Cloud and data storage providers hosting facial recognition databases may need to support new logging, retention, and deletion standards.
Companies building biometric AI tools should expect tighter procurement standards from Illinois public agencies, including bias testing and demographic accuracy disclosures.
Private sector use of facial recognition is not directly restricted by this bill, but Illinois already has BIPA, so combined exposure remains high for any company collecting facial data.
Bill is still in early committee stage (Referred to Assignments), meaning the final text and scope could shift significantly before any vote.
No specific penalty amounts, effective dates, or small business exemptions are spelled out yet in the available text.
What Should You Do
Ask your legal team to map any current contracts or data-sharing arrangements your company has with Illinois law enforcement involving video, images, or biometric data.
If you sell AI or biometric tools to government clients, have your product team prepare documentation on model accuracy, demographic performance, and audit logging now.
Retailers and property operators in Illinois should review camera footage sharing policies with police and confirm they align with existing BIPA obligations.
Assign someone to track this bill out of Assignments committee and flag any substitute language, since current text is thin and scope could expand.
Brief your security and compliance leads that Illinois is moving on police facial recognition, so procurement and vendor questionnaires can be updated proactively.
Who It Affects
Status Timeline
committee
Referred to Assignments
February 5, 2026