Law / United States / 
Illinois
Artificial Intelligence Safety Measures Act
An AI governance rule binding private bodies.
- Private right of action
- No
- Obligation class
- Governance, Reporting, Disclosure
- Audit expectation
- periodic
- Who audits it
- Independent third party
- Where the report goes
- Kept, Filed with regulator, Produced on request, Published summary, Published
What it requires
- A frontier developer is one that trains, or initiates the training of, a frontier model using more than 10^26 integer or floating-point operations of computing power; a large frontier developer is a frontier developer whose group had annual gross revenues over $500,000,000 in the preceding calendar year, and carries four of the duties below that the rest do not.
- Before or when you deploy a new or substantially modified frontier model, publish on your website a transparency report giving your website, a way for a person to reach you, the model's release date, its supported languages and output modalities, its intended uses, and any generally applicable restrictions on its use.NIST AI RMFMAP 2.2
- If you are a large frontier developer, add to that transparency report summaries of your catastrophic-risk assessments for the model, their results, the extent of any third-party evaluator involvement, and the other steps you took to meet your frontier AI framework for it.NIST AI RMFGOVERN 4.2
- If you are a large frontier developer, from write, implement, comply with and publish on your website a frontier AI framework covering catastrophic-risk assessment, mitigations, cybersecurity, internal governance, third-party evaluations, and risks from your own internal use of your frontier models.NIST AI RMFGOVERN 1.4
- If you are a large frontier developer, obtain an annual independent third-party audit of your compliance, and meet the Act's access, retention, and publication requirements for the audit results. Within 30 days of receiving the independent audit report, publish a high-level summary of the audit findings and a redacted copy of the report on your website and transmit the redacted report to the Agency and the Attorney General.NIST AI RMFMEASURE 1.3
- Report a critical safety incident to the Agency, the Illinois Emergency Management Agency and Office of Homeland Security, and to the Attorney General within 72 hours of learning facts sufficient to establish a reasonable belief that a critical safety incident has occurred.NIST AI RMFMANAGE 4.3
- Within 24 hours of discovering that a critical safety incident poses an imminent risk of death or serious physical injury, disclose it to an appropriate authority, including a law enforcement or public safety agency with jurisdiction over it.NIST AI RMFMANAGE 4.3
- Do not adopt or enforce a rule, policy or contract that stops a covered employee disclosing, and do not retaliate against a covered employee for disclosing, information they have reasonable cause to believe shows that your activities pose a specific and substantial danger to public health or safety from a catastrophic risk, or that you violated the Act.NIST AI RMFGOVERN 4.1
- If you are a large frontier developer, provide a reasonable internal process through which a covered employee can disclose that kind of information to you anonymously, and give that employee a monthly update on your investigation and on what you did in response.NIST AI RMFGOVERN 4.3
These lines are LexLint's reading of the law's text.
In the frameworks
- NIST AI RMF
- GOVERN 1.4The risk management process and its outcomes are established through transparent policies, procedures, and other controls based on organizational risk priorities.
- GOVERN 4.1Organizational policies and practices are in place to foster a critical thinking and safety-first mindset in the design, development, deployment, and uses of AI systems to minimize potential negative impacts.
- GOVERN 4.2Organizational teams document the risks and potential impacts of the AI technology they design, develop, deploy, evaluate, and use, and they communicate about the impacts more broadly.
- GOVERN 4.3Organizational practices are in place to enable AI testing, identification of incidents, and information sharing.
- MAP 2.2Information about the AI system’s knowledge limits and how system output may be utilized and overseen by humans is documented. Documentation provides sufficient information to assist relevant AI actors when making decisions and taking subsequent actions.
- MEASURE 1.3Internal experts who did not serve as front-line developers for the system and/or independent assessors are involved in regular assessments and updates. Domain experts, users, AI actors external to the team that developed or deployed the AI system, and affected communities are consulted in support of assessments as necessary per organizational risk tolerance.
1 more
- MANAGE 4.3Incidents and errors are communicated to relevant AI actors, including affected communities. Processes for tracking, responding to, and recovering from incidents and errors are followed and documented.
- NIST AI 600-1
- GAI-RISK-07Human-AI Configuration
- GAI-RISK-08Information Integrity
- GAI-RISK-09Information Security
- NIST AI 200-2 Draft
- OWASP LLM Top 10
- LLM03:2026Excessive Agency
- OWASP Agentic Top 10
- ASI09Human-Agent Trust Exploitation
- MIT mitigations Draft
- FINOS AIGF
- AIR-PREV-005System Acceptance Testing
- AIR-PREV-006Data Quality & Classification/Sensitivity
- AIR-PREV-024Human-in-the-Loop Action Approval Gate
- AIR-DET-004AI System Observability
- AIR-DET-011Human Feedback Loop for AI Systems
- AIR-DET-021Agent Decision Audit and Explainability
- ETSI EN 304 223
- 5.1.3-2Threats developers cannot resolve are passed to operators and on to end-users.
- 5.1.4-1Capability for human oversight designed in and maintained.
- 5.2.1-1Full inventory of assets, including their dependencies and connections.
- 5.2.2-5AI-specific incident management and recovery plans that are created, tested and maintained.
- 5.2.4-1Developers keep an audit trail of system design and post-deployment maintenance plans and offer it downstream.
- 5.3.1-1Users told where and how their data is used, accessed and stored, with developers informing operators.
Our reading of where this law's duties sit in each framework, and in the NIST AI RMF, line by line beside each duty above. It never says that running a control meets the law. How we read a framework against the law
Identifiers refer to ETSI EN 304 223 V2.1.1 (2025-12), © ETSI 2025, all rights reserved. ETSI owns the standard; no ETSI text (titles or sentences) is reproduced here. The standard is free to download from ETSI.
What it makes you log
Who may demand the log
Regulator, Auditor or notified body, Public
What the log must hold
Event time, System identity, Human involvement
Log retention
This is the retention period for unredacted information a developer withheld from a published compliance document under a permitted redaction. The retained copy of a third-party audit report itself carries a longer, deployment-linked floor: for as long as the audited frontier model remains deployed, plus five years after that.
- Unit
- Years
- As of
- Basis
- Fixed
- Minimum value
- 5
Logging duty
A large frontier developer must write and publish a documented frontier AI framework and a pre-deployment transparency report, and must retain an annual independent third-party audit report and grant the Agency and the Attorney General access to it on request. Every frontier developer must separately report a critical safety incident within 72 hours, giving the date, the reasons the incident qualifies, and a plain-language description, with an accelerated 24-hour disclosure where the incident poses an imminent risk of death or serious injury. None of these provisions names a log, record, or audit trail directly; each requires the developer to document, retain, or produce something that cannot be shown without a record, so the duty is implicit. The Agency and the Attorney General review submitted incident reports. Section 18 conditions a large frontier developer's separate disclosure-statement filing on developing, deploying, or operating a frontier model in this State, the Act's only territorial clause, but that clause is confined to Section 18's own filing duty and does not extend to the framework, transparency-report, audit, or incident-reporting duties in Sections 10 and 15, none of which carries a territorial qualifier of its own. A critical safety incident report and an unredacted audit report are themselves exempt from public disclosure under the Freedom of Information Act; only the published transparency report and the audit summary are public.
- Kind
- Implicit
- As of
- Provision
- Section 10(a) (frontier AI framework), 10(c) (transparency report), 10(d) (independent third-party audit) and 15(c) (critical safety incident report)
What this law does
The Artificial Intelligence Safety Measures Act splits its duties across two classes of developer. A frontier developer is one that trains, or initiates the training of, a frontier model using more than 10^26 integer or floating-point operations of computing power. A large frontier developer is a frontier developer whose group had annual gross revenues over $500,000,000 in the preceding calendar year.
Every frontier developer must publish a transparency report on its website before or when it deploys a new or substantially modified frontier model. Every frontier developer must also report a critical safety incident to the Illinois Emergency Management Agency and Office of Homeland Security and to the Attorney General within 72 hours of learning facts sufficient to establish a reasonable belief that one has occurred.
Where it discovers that a critical safety incident poses an imminent risk of death or serious physical injury, it must separately disclose that incident within 24 hours to an appropriate law enforcement or public safety authority. No frontier developer may retaliate against a covered employee who discloses, with reasonable cause, a specific and substantial danger to public health or safety from a catastrophic risk, or a violation of the Act.
A large frontier developer carries four further duties. It must write, implement and publish a frontier AI framework from . It must add summaries of its catastrophic-risk assessments to that transparency report. It must obtain an annual independent third-party audit and meet the Act's access, retention and publication requirements for the results.
And it must provide a reasonable internal process through which a covered employee can disclose that kind of information to it anonymously. The Act establishes civil penalties for violations and expressly creates no private right of action, and takes effect . The bill (as Senate Floor Amendment No. 2, further narrowed by Amendments No. 3 and No. 4) was approved by the Governor on .
When LexLint raises it
When your app profile says your app is a frontier developer.
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