Illinois Harassment Training Requirements: Coverage and Penalties

Illinois harassment training requirements obligate every employer with employees working in the state to provide sexual harassment prevention training to all employees at least once per calendar year, regardless of company size.¹ The rule has been in force since January 1, 2020, under the Workplace Transparency Act. The Illinois Department of Human Rights (IDHR) publishes a free model program employers can use, and companies that skip training face civil penalties.² Chicago layers extra hours on top of the state mandate, and restaurants and bars have their own supplemental duties.

Who Needs to Be Trained

The mandate has no minimum employee threshold. A solo operator with one hire and a national employer with an Illinois office are equally covered.¹ “All employees” means everyone on the payroll, including part-time and temporary workers. Training must be completed at least once per calendar year.

Employers pick between two options. Use the IDHR’s free model training, offered online in English and other languages, or build an in-house program that meets or exceeds the statutory content minimums.² Many employers use the state model as a base and add their own reporting procedures and policies on top.

What the Training Must Cover

Section 2-109(B) of the Illinois Human Rights Act sets four minimum content requirements:

An explanation of sexual harassment consistent with the Illinois Human Rights Act, covering both quid pro quo harassment and hostile work environment claims.
Concrete examples of unlawful conduct, not just abstract legal definitions.
A summary of federal and state legal protections against harassment, including remedies available to victims.
A description of employer responsibilities for prevention, investigation, and corrective action.¹

These are floors, not ceilings. A program can go further, and many do, particularly by adding bystander intervention content and separate modules for supervisors.

Chicago’s Added Requirements

Employers with operations inside Chicago face a stricter regime under the Chicago Human Rights Ordinance. These duties apply on top of the state mandate, so Chicago employers must meet both:

One hour of annual sexual harassment prevention training for every employee.
Two hours of annual sexual harassment prevention training for anyone who supervises or manages employees.
One hour of annual bystander intervention training for every employee.³

Bystander training is where Chicago goes beyond state law. Illinois does not require it; Chicago does. A Chicago non-supervisor needs at least two hours of training annually (one prevention, one bystander), and a Chicago manager needs at least three (two prevention, one bystander).⁴

Chicago penalties run from $5,000 to $10,000 per violation, and non-compliance can affect a business’s liquor license or eligibility for city contracts.

Extra Rules for Restaurants and Bars

Section 2-110 of the Illinois Human Rights Act imposes additional obligations on restaurants and bars. On top of the annual training every employer must provide, restaurants and bars must deliver supplemental training that includes:

Industry-specific scenarios, activities, or videos reflecting the restaurant and bar environment, where tipped-worker dynamics and customer interactions create distinct risks.
An explanation of how managers can be held personally and professionally responsible for harassment.
Availability in both English and Spanish.⁵

Restaurants and bars must also maintain a written sexual harassment prevention policy in English and Spanish, delivered to every new employee within their first calendar week. The written policy must include the definition of sexual harassment under Illinois and federal law, an internal reporting process, contact information for the IDHR and the EEOC, and a prohibition on retaliation.⁶ The written-policy mandate is specific to this industry; other employers are not required by Section 2-110 to have one, though it remains sound practice.

Remote and Multi-State Workers

The mandate applies to every employer with employees “working in this State,” and Illinois reads that phrase broadly.¹ Employees who work remotely from Illinois must be trained even when the employer is headquartered elsewhere. According to state guidance, employees based outside Illinois who regularly interact with Illinois-based colleagues should also be trained.

Multi-state employers end up with layered obligations. A company with offices in Chicago, New York, and California may need to satisfy three different regimes with different content, frequency, and hour rules. Building a single program to the most demanding standard and rolling it out company-wide is usually more workable than customizing by location.

Record-Keeping

Employers must keep a record of completed training and produce it for IDHR inspection on request. Acceptable formats include completion certificates, signed employee acknowledgments, and course sign-in sheets, kept on paper or electronically.⁷

The IDHR does not set a minimum retention period. Because the statute of limitations for a discrimination charge is currently two years, keeping records for at least that long, and preferably longer, is the safe course. Records you cannot produce during an audit have the same practical effect as training you never delivered.

Penalties for Skipping Training

Enforcement under Section 2-109 runs in sequence. If the IDHR determines a violation has occurred, it first issues a notice to show cause and gives the employer 30 days to come into compliance. If the employer still hasn’t complied after 30 days, the IDHR petitions the Illinois Human Rights Commission for a civil penalty order.¹ Penalties are deposited into the Department of Human Rights Training and Development Fund.

Chicago runs a separate enforcement track. Violations of the Chicago Human Rights Ordinance carry fines of $5,000 to $10,000 per violation and can jeopardize business licenses, liquor licenses, and eligibility for city contracts.

Training gaps also surface in harassment litigation. A plaintiff’s attorney will ask whether the employer maintained a compliant program, and missing years weaken common defenses that turn on the employer’s preventive efforts.

2026 Amendments Affecting Related Agreements

Effective January 1, 2026, Illinois amended the Workplace Transparency Act. The annual training mandate itself is unchanged, but the amendments reshape how employers can write harassment-related agreements:

Nondisclosure and confidentiality provisions in separation and settlement agreements must be more carefully scoped. Employers cannot restrict employees from making truthful statements about alleged unlawful employment practices or from reporting to government agencies.
Employment agreements cannot prohibit employees from engaging in concerted activity to address workplace conditions, including collective bargaining, union organizing, and discussing wages and working conditions.
Employers cannot impose terms that shorten statutes of limitations, force non-Illinois law to govern an Illinois employee’s claim, require out-of-state venues for disputes, or unilaterally declare that confidentiality is the employee’s preference.

Separation templates, settlement forms, and employment contracts drafted before 2026 should be reviewed against these limits. Allocating separate consideration for confidentiality terms and building in clear carve-outs for agency reporting and legal disclosures is now the safer approach.

1
Illinois General Assembly. 775 ILCS 5/2-109 – Sexual Harassment Prevention Training
2
Illinois Department of Human Rights. Sexual Harassment Prevention Training Program
3
City of Chicago. Sexual Harassment
4
American Legal Publishing. Chicago Municipal Code 6-10-040 Sexual Harassment
5
Illinois Department of Human Rights. Training Standards for Restaurants and Bars, Sexual Harassment Prevention
6
Illinois Department of Human Rights. Minimum Standards for Policy on Sexual Harassment Prevention for Restaurants and Bars
7
Illinois Department of Human Rights. Sexual Harassment Prevention: Frequently Asked Questions