Illinois AED requirements apply to physical fitness facilities that serve 100 or more people, and the core obligations come from the Physical Fitness Facility Medical Emergency Preparedness Act, 210 ILCS 74. If your facility is covered, you must keep at least one operable automated external defibrillator on the premises, have a trained user on staff during operating hours, maintain the device according to the manufacturer’s schedule, and adopt a written medical emergency plan. Meet all of those conditions and the Act shields you from most civil liability tied to AED use or non-use. Miss any one and you lose that protection while exposing yourself to graduated fines.
Which Facilities Are Covered
The Act reaches two categories of facilities. The first is any indoor or outdoor athletic facility owned or operated by a government entity (park districts, municipalities, townships) or by a school, college, or university, provided at least one employee supervises physical fitness activities. Swimming pools, stadiums, athletic fields, basketball courts, and tennis courts all fit here.1Illinois General Assembly. Illinois Code 210 ILCS 74 – Physical Fitness Facility Medical Emergency Preparedness Act
The second is any other public or private establishment, indoor or outdoor, that provides services focused on cardiovascular exertion or gaming. Private gyms and health clubs sit in this group. Facilities serving fewer than 100 total individuals are excluded from the Act entirely.1Illinois General Assembly. Illinois Code 210 ILCS 74 – Physical Fitness Facility Medical Emergency Preparedness Act
A note on schools. The Act does not impose a general AED mandate on school buildings. It reaches school-owned fitness facilities where employees supervise activities. Separately, Illinois education law requires secondary schools to include AED training in their curricula and directs school boards to distribute AED information to teachers and administrators at the start of each year.2Justia Law. Illinois Code 105 ILCS 110 – Critical Health Problems and Comprehensive Health Education Act
Where the AED Must Be Kept
Every covered facility must have at least one operable AED on the premises at all times. For outdoor facilities, the device has to sit in a building within 300 feet of where activities take place. That building must offer unimpeded, open access during events, and entrances must carry marked directions pointing to the AED.3Legal Information Institute. Illinois Administrative Code tit. 77, Section 527.600 – Automated External Defibrillators Required
When several facilities share the same floor of a building, a single AED can cover all of them, as long as it is within 300 feet of each and access is unimpeded from every direction. Placement is driven by distance and accessibility, not a one-per-room formula.3Legal Information Institute. Illinois Administrative Code tit. 77, Section 527.600 – Automated External Defibrillators Required
Staff Training
Illinois administrative code requires physical fitness facility staff to be trained in both CPR and AED use. At least one trained AED user must be present during all staffed business hours, and facilities have to line up enough trained staff and supervisors to avoid gaps in coverage.4Legal Information Institute. Illinois Administrative Code tit. 77, Section 527.800 – Training
The rule is different for people who are not employees. Volunteer coaches, referees, and other non-employee supervisors who use the facility during physical fitness activities are encouraged, but not required, to complete AED training.4Legal Information Institute. Illinois Administrative Code tit. 77, Section 527.800 – Training
For government and school-run outdoor facilities, the requirement is scoped to events: an AED and a trained user must be available during activities or events that are sponsored and supervised by an employee of the government unit, school, or university.3Legal Information Institute. Illinois Administrative Code tit. 77, Section 527.600 – Automated External Defibrillators Required
Professional CPR and AED certification courses for lay responders typically cost between $20 and $100 per person, depending on the provider and format.
Maintenance and the Written Emergency Plan
Every covered facility must maintain and test its AED according to the manufacturer’s guidelines. That means following the manufacturer’s schedule for verifying battery charge, checking electrode pad expiration dates, and running any self-diagnostic tests the device supports. The facility must keep a copy of the maintenance and testing manual both at the facility and with the AED itself.5Justia Law. Illinois Administrative Code, Part 527, Section 527.700 – Maintenance
Replacement electrode pads generally run $65 to $89 per set, and pads and batteries each have their own replacement cycles. Letting either expire means the AED can look ready and still fail to deliver a shock.
Covered facilities must also adopt a written medical emergency plan under Section 10 of the Act. Adopting and maintaining that plan is one of the three conditions that triggers the Act’s immunity protection.6Illinois General Assembly. Illinois Code 210 ILCS 74 – Physical Fitness Facility Medical Emergency Preparedness Act
Penalties for Non-Compliance
Penalties are graduated. For a first violation, whether the problem is a missing AED, no trained user, or no adopted emergency plan, the Director of Public Health may issue a written administrative warning with no monetary penalty. The facility can respond in writing to explain what it has done to correct the issue.7Illinois General Assembly. Illinois Code 210 ILCS 74/35 – Penalties
Monetary penalties start with the second violation:
- Second violation: a civil penalty of at least $1,500 but less than $2,000.
- Third or subsequent violation: a civil penalty of at least $2,000.
Fines are not automatic. The Director must give written notice of the alleged violation, offer the facility a chance to request a hearing before an impartial examiner, and issue a written decision based on the evidence. If a facility refuses to pay, the Attorney General can bring a court action to collect.7Illinois General Assembly. Illinois Code 210 ILCS 74/35 – Penalties
Enforcement begins with a complaint. The Illinois Department of Public Health or its representative inspects a facility after receiving a complaint that includes the complainant’s name, address, phone number, and a specific allegation. Anonymous or vague complaints do not trigger inspections.8Legal Information Institute. Illinois Administrative Code tit. 77, Section 527.900 – Complaints and Inspections
Civil Liability and the Statutory Immunity
The statutory fines are modest. The bigger financial exposure comes from civil suits. If someone suffers cardiac arrest at a facility and the AED fails because batteries were dead or pads were expired, the facility can face wrongful death or personal injury claims arguing that it had a duty to maintain the device, failed to do so, and that failure contributed to the harm. Settlements and verdicts in these cases can far exceed the Act’s civil penalties.
Illinois provides two layers of protection against that exposure, one for the person who uses the AED and one for the facility.
Immunity for the AED User
Under the Good Samaritan Act, a person who uses an AED in good faith, without compensation, and within the scope of their training is not liable for civil damages resulting from the emergency care. The only exception is willful and wanton misconduct, which is a much higher bar than ordinary negligence.9Illinois General Assembly. Illinois Code 745 ILCS 49/12 – Use of an Automated External Defibrillator; Exemption from Civil Liability for Emergency Care
Three conditions have to line up: good faith, no payment for the care, and action within the scope of training. A trained bystander who grabs the AED and follows the device’s prompts is squarely inside that protection.
Immunity for the Facility
The Physical Fitness Facility Medical Emergency Preparedness Act grants its own immunity to the person, government unit, or school district operating a covered facility. No right of action exists for the use or non-use of an AED at the facility, except for willful or wanton misconduct, if the operator has done three things: adopted a medical emergency plan, kept an AED on the premises, and maintained the AED according to the Department’s rules.10Illinois General Assembly. Illinois Code 210 ILCS 74/45 – Liability
Those three conditions are prerequisites, not suggestions. A facility that skips maintenance, lets electrode pads expire, or never adopts a written plan loses its statutory immunity and is left defending an ordinary negligence claim on its own.
Registration with EMS
Illinois once required AEDs to be registered with local EMS systems, but Public Act 95-0447 removed that mandate. Facilities are not required to register their devices with the state or with local EMS agencies. Voluntary notification is still useful: dispatchers who know an AED is on-site can direct a 911 caller to the nearest device while help is on the way.