When Illinois decided to regulate AI in hiring, it skipped the standard playbook. It passed no standalone AI statute and mandated no bias audit.

Instead, it amended the sixty-year-old Illinois Human Rights Act, making algorithmic discrimination a civil rights matter and enforced by the same agency that handles housing, credit, and employment complaints.

House Bill 3773 took effect January 1, 2026.

Jason Rosensweig is one of the few people in the country writing the rules that will govern it. As Senior Policy Advisor at the Illinois Department of Human Rights, he's drafting the implementing regulations — Subpart J — that will shape how thousands of Illinois employers, and the vendors selling into them, operate.

We get into:

• Why Illinois built the law on a civil rights chassis, and how that decision determines which doctrines apply and what evidence courts will demand
• How a single-issue bill about zip codes grew into a statewide notice regime
• Why the compliance mechanism is disclosure rather than an audit — and how the notice doubles as data infrastructure for future enforcement
• The ”influence or facilitate” standard, and why its reach covers far more of the employment lifecycle than most compliance teams have scoped for
• Why liability sits with employers rather than the developers who build the tools, and how Illinois vendor contracts are about to change in 2026
• Jason's blunt response to the claim that AI moves too fast for government to regulate

Jason holds a PhD from the University of Chicago's Committee on Social Thought and also teaches in the Northwestern Prison Education Project.