Illinois Governor JB Pritzker signed Senate Bill 315, enacted as the Artificial Intelligence Safety Measures Act, on 6 July 2026. The Act passed the Illinois General Assembly with bipartisan support and takes effect 1 January 2027. Illinois is the first US state to mandate annual independent third-party safety audits for developers of frontier AI systems.
The Act applies to 'covered developers', defined as entities that develop frontier AI models generating more than $500 million in annual revenue and trained using compute resources meeting a floating-point-operations-per-second threshold to be set by the Attorney General in rulemaking. Covered developers must: publish annual AI safety frameworks identifying foreseeable risks and mitigation measures; commission independent third-party audits at least once per calendar year; report safety incidents to the Illinois Attorney General within designated timelines; and maintain whistleblower protections for employees who disclose AI safety concerns. The Act places Illinois alongside California and New York in requiring transparency obligations on developers of large-scale AI systems.
Frontier AI developers with revenues above $500 million whose models are used by Illinois residents or deployed by Illinois-based businesses must prepare their first independent audit cycle before 1 January 2027. Covered developers must designate responsible personnel, document AI safety frameworks, and establish incident reporting channels. AI auditing firms capable of assessing frontier models at the scale the Act contemplates will face increased demand. Downstream deployers that rely on covered developers' APIs should obtain contractual representations regarding audit status and compliance.
The Act's obligations apply only to developers meeting both the revenue and compute thresholds; smaller developers are not covered. The Attorney General retains rulemaking authority to define the compute threshold, leaving technical scope open pending final rules. The Act contains an exemption for research and academic use. Civil enforcement is vested in the Illinois Attorney General with civil penalties prescribed in the statute. No private right of action is created.
Licentium advises clients on US AI regulatory obligations and may assist directly or through its partner network. Covered developers, their enterprise customers, and downstream deployers are welcome to contact us. Work we undertake includes US state AI law compliance, safety framework documentation, independent audit preparation support, AI vendor due diligence, incident response protocols, and AI regulatory monitoring across US and EU jurisdictions.