Illinois Governmental Ethics Act: Filings, Deadlines, and Conduct Rules

The Illinois Governmental Ethics Act, codified at 5 ILCS 420, requires thousands of state and local officials, employees, and candidates to file an annual Statement of Economic Interests, follow conflict-of-interest rules, and observe conduct restrictions tied to lobbying, honoraria, and outside compensation. The core obligation for most people it covers is simple: file a verified disclosure form by May 1 each year, or face escalating penalties that end in forfeiture of office.

Who Has to File and Comply

The Act reaches an unusually broad cross-section of Illinois government. At the state level, it covers members and candidates for the General Assembly, elected executive branch officers, judges at every level, gubernatorial appointees subject to Senate confirmation, members of state-created boards and commissions, retirement system board members, and state employees who hold significant authority. That last category includes department heads, employees with decision-making power over contracts worth $5,000 or more, people who issue rules and regulations, those who approve professional licenses, procurement officers, and anyone supervising 20 or more state employees.¹

At the local level, the Act covers elected officials of every unit of local government, including counties, municipalities, townships, school districts, and community college districts. It also reaches appointed members of governing boards, zoning boards, plan commissions, and county boards of review. Local employees meet the filing threshold through parallel authority tests: department heads, employees responsible for contracts of $1,000 or more, license and permit approvers, and supervisors of 20 or more employees. School district employees who hold an administrative or chief school business official endorsement must comply as well, as must members of local pension fund boards.² In a single mid-sized county like Kane County, this works out to nearly 200 government agencies and roughly 6,000 individual filers.³

What the Statement of Economic Interests Asks For

The disclosure form was substantially rewritten in 2021 and 2022. For the preceding calendar year, filers must report information about themselves, their spouses, and their minor children in eight categories:²

Any single asset valued above $10,000, including stocks, bonds, sector mutual funds, ETFs, commodity futures, investment real estate, trust interests, and business or partnership interests. Personal residences, vehicles, bank accounts, government bonds, diversified funds, annuities, pensions, and retirement savings plans are excluded.
Any source of income exceeding $7,500, other than compensation from the position that triggered the filing.
Any sale or transfer of an asset producing capital gains above $7,500, along with the transaction date.
Any single debt above $10,000, excluding standard consumer loans such as mortgages, credit cards, and student loans.
Any unit of government where the filer or spouse holds employment, a contract, or an office other than the one triggering the filing.
The identity of any registered lobbyist with whom the filer has an economic relationship or a family connection.
The source of any gift or honorarium, or aggregate gifts, valued above $500.
Immediate family members living with the filer who are employed by a public utility.

Filers disclose the types and sources of their financial interests, not specific dollar amounts or valuations.⁴ Beginning December 1, 2025, and every five years after, the Secretary of State must adjust the dollar thresholds for inflation using the Consumer Price Index.²

Every statement must be verified, dated, and signed, with a declaration acknowledging that a willfully false or incomplete filing is punishable by a fine of up to $2,500, imprisonment of up to one year, or both.² All filings are public records available online and in person at the filing office.⁵

When and Where to File

The annual deadline is May 1. State-level officials and employees file with the Illinois Secretary of State; local officials and employees file with the county clerk in the county where their unit of government’s principal office is located.² Candidates must file no later than the end of the qualifying period for nomination or election, and new appointees or employees must file at the time of appointment if it falls before May 1.

The Secretary of State runs an electronic filing system; filers who are also subject to the State Officials and Employees Ethics Act must have their statement reviewed by an ethics officer before submission.⁶⁷⁸ Check with your filing officer before the deadline to confirm the method.

What Happens If You File Late or Not at All

The late-filing penalty structure is tiered and moves fast:²

Statements filed between May 2 and May 15 trigger a $15 fee.
Starting May 16, the penalty becomes $100 per day.
Anyone who still has not filed by May 31 forfeits the office or position that required the filing.

Administrative officers may waive these penalties for serious illness or military service. Non-filers who miss the May 31 deadline are referred for prosecution: to the State’s Attorney for local filers, and to the Office of the Attorney General for state-level filers.⁹ A willfully false or incomplete statement carries separate criminal exposure, with a fine of up to $2,500, up to a year in jail, or both.

Conduct Rules Beyond Disclosure

The Act also imposes hard prohibitions on certain conduct, concentrated on legislators and local elected officials. Legislators may not engage in compensated lobbying that conflicts with their duties, accept compensation for their legislative duties beyond what state law provides, participate in representation cases before the Illinois Court of Claims or the Illinois Workers’ Compensation Commission, or accept honoraria. Honoraria received in violation must be turned over to the State Treasurer for deposit in the General Revenue Fund. County, municipal, and township officials face parallel lobbying limits; an elected or appointed county official, for instance, cannot lobby the General Assembly or a state executive office on behalf of an entity that is registered to lobby the county the official serves.¹⁰ Lobbying violations and improper representation-case participation are Class A misdemeanors, punishable by up to 364 days in jail and a fine up to $2,500. Taking unauthorized compensation is a petty offense.

Gubernatorial appointees to boards, commissions, authorities, and task forces have an additional set of rules. They must disclose any state contracts they hold, and they, their spouses, and immediate family members are barred from entering into state contracts that would create a conflict of interest. Failure to disclose is a business offense carrying a $1,001 fine.¹⁰ Members of Governor-appointed boards and commissions are also limited to compensation for one meeting per seven-day period.¹¹

Separate ethical principles in Article 3 address use of confidential information, improper influence over state agencies, and conflict management for legislators, including when to abstain from voting. Guidance for close economic associates of legislators is explicitly non-binding under the statute.

What This Act Does Not Cover

Several rules that people often assume live in the Governmental Ethics Act are actually in other Illinois statutes. The state gift ban, whistleblower protections, restrictions on political activity during work hours, and revolving-door limits on post-employment lobbying and contracting are in the State Officials and Employees Ethics Act (5 ILCS 430), not the Governmental Ethics Act, though the Governmental Ethics Act does require filers to disclose gifts above $500.¹ The revolving-door rule, found in Section 5-45 of the State Officials and Employees Ethics Act, imposes a one-year cooling-off period on former state personnel who participated in awarding contracts worth $25,000 or more to a specific entity.¹² Lobbying registration itself is governed by the separate Lobbyist Registration Act. And the Executive Ethics Commission, which enforces ethics rules for executive branch employees, has no direct role in enforcing the Governmental Ethics Act’s disclosure provisions; that work is handled by the Secretary of State and county clerks as filing officers.¹³

Local Government Administrative Duties

Local governments have their own responsibilities under the Act, independent of what their individual officials must file. By February 1 each year, the chief administrative officer of each unit of local government must certify a list of all individuals within the organization who are required to file and submit that list to the appropriate filing officer.² Local governments can also adopt disclosure rules stricter than the state’s.

Under the separate State Officials and Employees Ethics Act, every unit of local government and school district must adopt an ordinance or resolution regulating political activities and gift solicitation and acceptance by its officers and employees. Those local rules must be no less restrictive than the state law. The Illinois Attorney General’s office publishes a model ethics ordinance covering prohibited political activity, a gift ban, penalties, and optional provisions for a local ethics advisor and ethics commission.¹⁴

1
Illinois Secretary of State. Illinois Governmental Ethics Act Publication
2
Illinois General Assembly. Illinois Governmental Ethics Act – Article 4A
3
Kane County Clerk. Kane County Statement of Economic Interests Portal
4
ISACO Illinois. Statement of Economic Interests Guide
5
Illinois Secretary of State. Statement of Economic Interests Search
6
Illinois Secretary of State. Statement of Economic Interests Electronic Filing
7
DuPage County Clerk. DuPage County Statement of Economic Interests
8
McLean County. McLean County Statements of Economic Interests
9
Illinois Secretary of State. Secretary of State – Economic Interests
10
Illinois General Assembly. Illinois Governmental Ethics Act Full Text
11
Illinois General Assembly. Illinois Governmental Ethics Act – Article 3B
12
Illinois General Assembly. Revolving Door Information
13
Executive Ethics Commission. What Is the Executive Ethics Commission
14
Illinois Attorney General. Model Ethics Ordinance Guide