| Update Applicable to: | Effective Date |
| All Covered Employers, Regardless of Size | January 1, 2026 October 1, 2026: State Will Release Model Program |
What happened?
On July 2, 2025, Illinois Governor J.B. Pritzker signed Senate Bill 1422 into law, expanding the Human Trafficking Recognition Training Act to include lodging establishments, restaurants, and truck stops, and strengthening employer responsibilities and enforcement mechanisms.
Overview:
Illinois expanded its Human Trafficking Recognition Training Act to include other employers, strengthening employer responsibilities and enforcement mechanisms.
- Senate Bill 1422 broadens its scope and improves compliance.
New Requirements
- Training Mandate: Employers must provide at least 20 minutes of training to employees:
- Within 6 months of hiring.
- And every 2 years thereafter.
- Training Content must include:
- Definition of human trafficking and child exploitation.
- How to identify individuals most at risk.
- Differences between labor and sex trafficking.
- Guidance on reporting and responding to trafficking.
Employers may use their own or third-party training programs, or adopt the curriculum developed by the Illinois Department of Human Services, which must be published by October 1, 2026.
Enforcement & Penalties
- Starting October 1, 2026, local governments and law enforcement may monitor compliance.
- Employers found in violation will receive a 30-day notice to correct the issue.
- If not corrected, the Attorney General or State’s Attorney may file a civil action.
- Violations are classified as business offenses, with fines up to $1,500 per offense.
Additional Information:
- While employers must begin training employees by January 1, 2026, formal enforcement by state and local authorities will begin on October 1, 2026—coinciding with the release of the state-developed training curriculum.
- Although employers must begin complying with training requirements on January 1, 2026, they are not required to use the state-developed curriculum, which will be published by October 1, 2026. Employers may use their own or third-party training programs that meet the law’s content standards.
Source References
- Illinois SB 1422 – HUMAN TRAFFICKING RECOGNITION – (Public Act 104-0099)
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