Governor JB Pritzker signed the Artificial Intelligence Safety Measures Act (AIMSA) on 6 July 2026. The Act applies to large frontier developers, defined as companies that develop frontier AI models, and creates the first US state mandate for annual independent third-party audits of AI safety governance. Core provisions take effect 1 January 2027. The independent audit requirement takes effect 1 January 2028. The Illinois Emergency Management Agency and Office of Homeland Security, in consultation with the Attorney General, administer the regulatory programme.
AIMSA requires large frontier developers to create, implement, publish, and annually update a frontier AI safety framework addressing catastrophic-risk assessment, risk mitigations, governance procedures, cybersecurity controls, third-party evaluation standards, and internal-use catastrophic-risk analysis. Covered developers must file transparency reports with the Illinois Emergency Management Agency and Office of Homeland Security before deploying any new or substantially modified frontier model. Annual independent third-party audits of the safety framework are mandatory from 1 January 2028. Civil penalties apply for violations.
Large frontier developers whose models are deployed in Illinois or accessible to Illinois users fall within AIMSA's scope, regardless of where the developer is domiciled. Both Illinois-based companies and out-of-state or foreign developers are in scope. The Act defines covered employees and prohibits retaliation against those who report non-compliance. The threshold for what constitutes a large frontier developer will be set through rulemaking by the administering agencies.
AIMSA draws on model legislation developed in California and New York. Open questions include how regulators will define frontier model and set compute thresholds through rulemaking, how the Illinois obligations will interact with federal AI governance proposals pending in Congress, and whether developers serving Illinois users exclusively through API access fall within scope.
Licentium advises AI developers and deployers on US state AI law compliance, including readiness assessments under AIMSA and frontier model governance programme design. We maintain a partner network with US counsel for safety framework drafting and regulatory filing support. Work we undertake includes AI governance programme design, frontier model risk assessment, transparency report preparation, regulatory filing assistance, and AI compliance audit preparation.