Framework · Illinois HB 3773
Illinois HB 3773 evidence for the AI that screens people.
Section 2-102(L) of the Illinois Human Rights Act has been in force since 1 January 2026, with discriminatory-effect liability, a zip-code-proxy ban, and a notice duty for AI in employment decisions. Meilynx produces the runtime evidence for the AI-traffic slice, and the notice and scoping determination stay yours.
Effect, proxies, notice.
Public Act 103-0804 reaches AI used in recruitment, hiring, promotion, discipline, discharge, and terms of employment.
- Discriminatory-effect liability for AI used in recruitment, hiring, promotion, discipline, discharge, or terms of employment with a discriminatory effect on a protected class (§2-102(L)(1)).
- The zip-code-proxy ban: zip codes may not be used as a proxy for a protected class (§2-102(L)(1)).
- Notice to employees and applicants that AI is used for those purposes (§2-102(L)(2)).
- Rules on the notice from the Illinois Department of Human Rights, which the statute directs to adopt them.
Statutory duties, to runtime evidence.
A specific Meilynx control for each obligation the proxy can substantiate, and the artifact it produces. The notice, the scoping determination, and the feature exclusion stay attested in your program.
Illinois HB 3773 → Meilynx controls (AI-traffic slice)
| Requirement | How Meilynx maps | Examination artifact |
|---|---|---|
Know which AI systems touch recruitment, hiring, promotion, discipline, or discharge IL HB 3773 · §2-102(L)(2) | The inventory of hiring-AI models and providers is derived from live traffic and enforced by runtime model allow-listing. The set of systems the notice must cover starts from what actually runs. | Hiring-AI system inventory, generated from traffic |
Keep a record of AI-assisted employment decisions that survives a discriminatory-effect claim IL HB 3773 · §2-102(L)(1) | Each hiring-AI request, response, and governance decision is captured inline at the proxy and sealed into a tamper-evident, hash-chained record that shows what the AI was asked and what it answered. | Hash-chained decision audit trail for the period |
Show zip codes are not used as a proxy for a protected class IL HB 3773 · §2-102(L)(1) | Personal-data detection over hiring-AI traffic evidences which candidate data actually reached each model. The feature exclusion itself is your decision, carried as feature documentation and data-flow records. | Candidate personal-data findings by tool; feature documentation, attested |
Detect unapproved changes to the system as deployed IL HB 3773 · §2-102(L)(1) | Prompt-drift and tool-grant-drift detection flag unapproved changes to hiring-AI configuration against approved baselines. Liability attaches to the system as it runs, not as it was designed. | Drift findings against approved baselines |
Evidence the notice to employees and applicants IL HB 3773 · §2-102(L)(2) | The notice is an employer act, drafted to the rules the Department of Human Rights adopts, and Meilynx never sends it. The package carries the notice text, delivery records, and dates as attested evidence. | Notice evidence and the systems each notice must cover, attested |
Know which AI systems touch recruitment, hiring, promotion, discipline, or discharge
IL HB 3773 · §2-102(L)(2)
Maps to · The inventory of hiring-AI models and providers is derived from live traffic and enforced by runtime model allow-listing. The set of systems the notice must cover starts from what actually runs.
Examination artifact · Hiring-AI system inventory, generated from traffic
Keep a record of AI-assisted employment decisions that survives a discriminatory-effect claim
IL HB 3773 · §2-102(L)(1)
Maps to · Each hiring-AI request, response, and governance decision is captured inline at the proxy and sealed into a tamper-evident, hash-chained record that shows what the AI was asked and what it answered.
Examination artifact · Hash-chained decision audit trail for the period
Show zip codes are not used as a proxy for a protected class
IL HB 3773 · §2-102(L)(1)
Maps to · Personal-data detection over hiring-AI traffic evidences which candidate data actually reached each model. The feature exclusion itself is your decision, carried as feature documentation and data-flow records.
Examination artifact · Candidate personal-data findings by tool; feature documentation, attested
Detect unapproved changes to the system as deployed
IL HB 3773 · §2-102(L)(1)
Maps to · Prompt-drift and tool-grant-drift detection flag unapproved changes to hiring-AI configuration against approved baselines. Liability attaches to the system as it runs, not as it was designed.
Examination artifact · Drift findings against approved baselines
Evidence the notice to employees and applicants
IL HB 3773 · §2-102(L)(2)
Maps to · The notice is an employer act, drafted to the rules the Department of Human Rights adopts, and Meilynx never sends it. The package carries the notice text, delivery records, and dates as attested evidence.
Examination artifact · Notice evidence and the systems each notice must cover, attested
What you show an agency or a plaintiff's counsel.
The audit trail renders into an evidence package scoped to the AI-traffic slice. Each control is classified as proxy-verified runtime evidence or attested in your program.
In the package
- Hiring-AI system inventory, auto-populated from traffic.
- Candidate personal-data findings per tool and vendor.
- Notice evidence and the systems each notice must cover (attested).
- Tamper-evident decision audit trail across the reporting period.
- Obligation timeline: Illinois and NYC in force, Colorado readiness, EU AI Act pointer.
Illinois HB 3773 and the proxy.
What does Illinois HB 3773 require?
Public Act 103-0804 amended Section 2-102(L) of the Illinois Human Rights Act (775 ILCS 5/2-102(L)) with effect from 1 January 2026. It is a civil rights violation to use AI in recruitment, hiring, promotion, discipline, discharge, or terms of employment in a way that has a discriminatory effect on a protected class, or to use zip codes as a proxy for a protected class, and employers must notify employees and applicants that AI is used for those purposes.
Does the preset satisfy HB 3773 on its own?
No runtime product could. The notice, the scoping call on which systems use AI for employment purposes, and the exclusion of zip codes as a feature all happen outside the proxy. What the proxy substantiates from live traffic carries proxy-verified evidence, and everything else is marked as attested.
How does Illinois relate to New York City and Colorado?
Section 2-102(L) sets discriminatory-effect liability, the zip-code-proxy ban, and the notice duty. The annual independent bias audit is a New York City Local Law 144 requirement, which Meilynx evidences and never performs, and Colorado SB 26-189 is covered as readiness ahead of 1 January 2027. All three sit under one employment-AI preset.
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