I Read 201 Chicago Job Postings Looking for Illinois' New AI Notice. Not One Mentions Illinois.

TL;DR: Illinois HB 3773 has required employers to notify people when AI is used in hiring since January 1, 2026. On August 15, 2026 I pulled 201 live job postings for Chicago and Illinois roles across 20 employers and read every one. 54 postings carried some notice that the employer uses AI in hiring, but all 54 came from two companies, and zero of the 201 mentioned Illinois, HB 3773, or the Illinois Human Rights Act. The most detailed notice a Chicago applicant will see in this sample explains their rights under a New York City ordinance. None of that establishes wrongdoing by anyone: the Illinois rules defining what notice even looks like were proposed on May 15, 2026 and postponed on June 2, so an employer can reasonably conclude its tools are out of scope. This is a count of what is published, not legal advice.

Seven months after the law took effect, nobody had counted whether it changed the page an applicant actually reads. So I did.

What does the Illinois law actually require?

I read the enrolled statute rather than the coverage of it. Public Act 103-0804 amends the Illinois Human Rights Act and closes with "Section 99. Effective date. This Act takes effect January 1, 2026." The operative language is new subdivision (L). Paragraph (1) covers AI use "[w]ith respect to recruitment, hiring, promotion, renewal of employment, selection for training or apprenticeship, discharge, discipline, tenure, or the terms, privileges, or conditions of employment." Paragraph (2) makes it a violation "[f]or an employer to fail to provide notice to an employee that the employer is using artificial intelligence for the purposes described in paragraph (1)."

Two things about that text are worth seeing directly. First, the definition of AI is enormous: "a machine-based system that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions." An ATS that ranks resumes plausibly infers outputs from inputs. Second, the notice duty is written toward "an employee," and the word "applicant" appears nowhere in subdivision (L), even though paragraph (1) plainly reaches recruitment. The statute hands that gap to the regulator in the very next sentence, which directs the Department to adopt rules on "the circumstances and conditions that require notice, the time period for providing notice, and the means for providing notice."

Those rules do not exist yet. Seyfarth's employment group documented the sequence: the Illinois Department of Human Rights published proposed amendments to Title 44, Part 2520 on May 15, 2026, then announced on June 2 that it was postponing the rulemaking and cancelling its June 10 hearing, with no revised timeline. The draft is withdrawn. The statutory duty is not.

How did I count this?

On August 15, 2026 I pulled every live posting from 44 employer job boards through Greenhouse's public board API (boards-api.greenhouse.io/v1/boards/{board}/jobs?content=true), which returns the full posting body as the applicant sees it. I filtered to postings whose location field names Chicago, Illinois, or a city followed by IL. That produced 201 postings across 20 employers.

I then searched every posting body for language disclosing employer use of AI in recruiting and read each hit by hand. The false positives matter: a pattern matching AI near "record" catches "track record of building AI products" in eight companies' job requirements, which is a job description, not a notice. Finally I followed every candidate privacy link the postings carry, on the theory that a link at the bottom of the application is the most generous reading of "notice."

What did 201 Chicago postings show?

54 of 201 postings carried a notice that the employer uses AI in the hiring process. All 54 came from two employers. Braze accounts for 50 of them and Reddit for 4. The other 147 postings, from 18 employers, said nothing about the employer using AI to evaluate applications.

Zero of the 201 postings referenced Illinois, HB 3773, the Illinois Human Rights Act, or 775 ILCS. Not one.

The notice a Chicago applicant is most likely to encounter is Braze's, and it is scoped by its own terms to somewhere else. It reads: "Pursuant to New York City Local Law 144, for roles based in New York City, or if you reside in New York City, you have the right to request an alternative selection process or a reasonable accommodation instead of AI-assisted review." Braze publishes real detail, including a bias audit page for candidates, and it appears on the Chicago listing because the boilerplate is global. An applicant in Chicago reads it and learns about a New York right.

One more hit runs backwards. A Peloton posting in the Illinois set restricts AI use by the candidate, stating the company does "not permit the use of AI tools during any stage of the application and interview process." Rules aimed at the applicant were as visible here as disclosures aimed at the employer.

Does the notice show up anywhere else?

This is where the picture improves slightly. Of the 20 employers, three more disclose AI use in a document linked from the posting rather than in the posting itself, giving 5 of 20 with a disclosure reachable at all.

Datadog's candidate legal notices are the most complete thing I found: "Datadog may use automated employment decision tools ('AEDT'), which incorporate artificial intelligence and machine learning technologies, during the application and hiring process," plus an opt-out and an independent auditor's review. Databricks discloses AI transcription and summarization of interviews. Webflow's applicant privacy notice is the most consequential sentence in the whole count: "we may use artificial intelligence (AI) to conduct initial screening interviews," where "an AI agent will ask you structured questions" and responses "will be recorded, transcribed, and may be evaluated and scored by the AI."

That is exactly the scenario the Illinois notice provision was written for, and you reach it by clicking a link most applicants never click. The remaining tally: 13 of 20 employers published nothing I could locate, and 2 more (Chime and Amount) returned 403 or timed out, so I record them as unread rather than empty. Across all 44 boards I harvested, only 22 employers linked any candidate privacy notice from their postings at all.

Does a missing notice mean anyone broke the law?

No, and I want to be blunt about that, because the count is easy to misread. Every number above measures publication, not compliance.

An employer only owes a notice if it is using AI within the meaning of the Act. Whether a keyword filter, a scheduling assistant, or an ATS ranking column meets that definition is unsettled, and the agency that was going to settle it pulled its draft in June. The withdrawn rules would have swept in any system that "influences or facilitates" a decision, broad enough that many employers reasonably read the law as unresolved. An employer using no covered tool owes no notice and its silence is correct. One that gives notice by email or intranet page would not appear in my count either, because I could only read what is public.

What would change my mind?

A bigger and less lopsided sample. Mine is 20 employers on one ATS, skewed toward technology companies that post publicly and write long privacy notices. Illinois' hospital systems and staffing agencies run on Workday and iCIMS tenants I did not read, and staffing firms are exactly the intermediaries the withdrawn rules would have pulled in as agents. If someone repeats this on 500 Workday postings and finds Illinois-specific notices, I sampled the wrong internet.

The pattern still rhymes with something this site keeps running into: a disclosure obligation gets satisfied by whoever already had a template for a different jurisdiction, and everyone else waits to see whether anyone checks. New York has had a bias audit mandate with actual enforcement since 2023, so I ran the same count on 38 NYC employers to see what a mature version of this law produces. It produces about the same thing. Meanwhile the claim that AI is already making these decisions at scale remains much better marketed than it is documented. Two of my 20 employers say in writing that software scores applicants. Eighteen do not say anything, and right now Illinois has not told them what saying something is supposed to look like.