HB 3773 compliance checklist
Build the AI hiring compliance file before review starts.
Public Act 103-0804, often searched as HB 3773, amended the Illinois Human Rights Act for employer use of artificial intelligence in employment decisions. This checklist focuses on the practical file: tools, evidence, notice-readiness, assumptions, and counsel handoff.
Core checklist
What belongs in the first-pass file.
1. Company and Illinois exposureRecord hiring locations, applicant geography, employee footprint, and the business owner for the review file.
2. Tool inventoryList ATS, HRIS, sourcing, chatbot, assessment, video interview, scheduling, ranking, matching, and internal AI tools that touch employment workflows.
3. Employment touchpointsMap each tool to recruiting, hiring, promotion, training selection, discipline, discharge, tenure, or employment terms.
4. Evidence labelsSeparate confirmed use, vendor-confirmed documentation, client-reported use, public signals, unknowns, and counsel-review items.
5. Vendor evidence gapsTrack AI feature descriptions, data inputs, validation/bias materials, human review controls, model updates, and notice support.
6. Notice-readinessDocument whether notice language, delivery process, recordkeeping, and approval responsibility are ready for review.
7. ZIP-code and proxy-risk questionsFlag any location, distance, demographic, scoring, or targeting inputs that need review for protected-class proxy concerns.
8. Approval trailTrack who reviewed the file, what changed, what remains open, and what needs attorney or leadership approval.
This checklist is educational workflow support, not legal advice. Public Act 103-0804 and IDHR rulemaking can affect final obligations. Use attorney review before relying on notices, policies, or legal conclusions.
Operating labels
Use labels that make the file honest.
| Label | Meaning | Next action |
|---|---|---|
| Confirmed | Employer or vendor evidence supports tool use. | Attach evidence and route for review. |
| Public signal | Found on public hiring, careers, vendor, privacy, or job-posting surfaces. | Confirm with the employer or vendor before relying on it. |
| Client-reported | The employer reports tool use, but evidence is not attached yet. | Request documentation or responsible-party confirmation. |
| Unknown | The tool or feature needs confirmation. | Assign an owner and follow-up date. |
| Counsel review | Legal sufficiency, notice wording, or business/legal risk needs legal review. | Move to the counsel handoff packet. |
Next step
Use AegisReview when the checklist turns into a real file.
The Checklist identifies what to gather. The Compliance Snapshot organizes the file, evidence gaps, notice-readiness notes, and counsel-review questions.