The Illinois Workplace Transparency Act (SB 75, effective January 1, 2020) amends the Illinois Human Rights Act to require every employer with one or more Illinois-based employees to provide sexual harassment prevention training to every employee annually — regardless of company size, industry, or whether employees are part-time, remote, or independent contractors. The annual deadline is December 31 of each calendar year, and the Illinois Department of Human Rights (IDHR) is the enforcement agency.
This guide is built for Illinois HR managers, single-location small employers, and multi-state operators who need a clear read on the SB 75 annual mandate and what the December 31, 2026 deadline actually requires.
What does the Illinois Workplace Transparency Act actually require?
SB 75 amended the Illinois Human Rights Act (775 ILCS 5/) to add three meaningful obligations on every Illinois employer with one or more Illinois-based employees. First, annual sexual harassment prevention training for every employee — full-time, part-time, short-term, seasonal, remote-from-Illinois, and (effective January 1, 2020) independent contractors as well. Second, annual disclosure to the IDHR of the total number of final adverse administrative or judicial decisions involving sexual harassment or discrimination in the previous year — the disclosure deadline is July 1 each year. Third, restrictions on nondisclosure agreements covering sexual harassment claims — an employee cannot be required to sign an NDA covering harassment as a condition of employment or settlement, except in narrow circumstances spelled out in the Act. The training requirement is the most operationally significant for most HR teams. For broader context, see the best LMS for multi-state sexual harassment training rollout.
The “one employee” threshold means SB 75 applies to every Illinois employer — a 3-person dental office in Naperville is in scope, a 50,000-employee multi-state operator with 800 Illinois-based employees is in scope, and a 12-person tech startup with two remote Illinois employees is in scope. There is no minimum-size exemption. Coggno’s Illinois Harassment and Discrimination course is built specifically for the SB 75 content requirements.
What training content does SB 75 specifically require?
The IDHR-published model training defines the content floor. The training must cover six elements at a minimum. First, an explanation of sexual harassment consistent with the Illinois Human Rights Act definition. Second, examples of conduct that constitute unlawful sexual harassment. Third, a summary of relevant federal and state statutory provisions concerning sexual harassment, including remedies available to victims. Fourth, a summary of responsibilities of employers in the prevention, investigation, and corrective measures of sexual harassment. Fifth, information regarding the Illinois Department of Human Rights and its enforcement role. Sixth, instruction on how employees can report harassment and the protections against retaliation. Coggno’s Illinois SB 75 course is structured around the IDHR model curriculum. For broader content guidance, see how to choose legally-compliant sexual harassment training.
An employer can use the IDHR-published model training itself (available free from the state) or a third-party course that meets or exceeds the model content. The catch with the free state model: it is a basic narrated slideshow without interactivity, scoring, or LMS-compatible tracking. For employers running 50 or more employees, the administrative cost of tracking completion through email attachments is usually higher than the per-seat cost of an LMS-delivered course. The Introduction to Illinois Harassment and Discrimination course provides a foundational version for industries with high seasonal turnover.
How does the Illinois training rule cover independent contractors and part-time employees?
SB 75 explicitly amended the Illinois Human Rights Act to cover independent contractors as well as employees — making Illinois one of the few states where independent contractors are protected from harassment under state law and where the training requirement extends to contractor populations. A construction GC running a Chicago job site with 12 W-2 employees and 30 1099 framing contractors needs to provide training to all 42 individuals. A media company with 4 staff editors and 25 freelance writers in Illinois has the same 29-person training population. Part-time employees, short-term hires, and remote employees who reside in Illinois are also covered. Coggno’s Sexual Harassment Prevention in Illinois Spanish course covers the Spanish-language version for employers with Spanish-primary staff and contractors. See sexual harassment training and workplace culture impact for the broader case for inclusive deployment.
Restaurant and hospitality employers have an additional layer. SB 75 also amended 820 ILCS 95/ to require restaurants and bars in Illinois to provide an industry-specific sexual harassment training that covers the unique dynamics of food and beverage service. The general SB 75 training does not satisfy the restaurant-specific rule — restaurants and bars need both. The Illinois Restaurant Association and the IDHR jointly published a model for the restaurant-specific version. For Spanish-speaking restaurant staff, the Illinois: Prevención del acoso sexual para empleados course covers the general SB 75 floor in Spanish.
What is the actual December 31, 2026 deadline workflow?
Every Illinois employee (and 1099 contractor) must complete training by December 31, 2026 — and again by December 31 each subsequent year. There is no rolling 12-month deadline; the calendar year is the unit. An employee hired in November 2026 must complete the training by December 31, 2026 unless the employer documents a reasonable basis for extending to a January 2027 onboarding cohort. Most Illinois HR teams structure the year around a Q4 rollout: late October launch, mid-December completion deadline, end-of-year reporting reconciliation. A 200-employee multi-location operator with three Illinois sites typically structures the Q4 push like this — launch on October 15, completion deadline December 15, exception handling December 16-31, and a final reconciliation report on January 5 confirming 100% completion. The training completion metrics that prove compliance to auditors piece covers what those records have to show.
The IDHR can initiate enforcement actions for failure to train, and civil penalties under 775 ILCS 5/8B-101 range from $500 per violation for an employer with fewer than 4 employees up to $5,000 per violation for a third or subsequent violation by an employer with 15 or more employees. The financial exposure is small per incident but multiplies fast across a workforce — a 200-employee operator that fails to train 35 employees is looking at potential exposure across each individual training failure. See state-by-state compliance training changes for 2026 for the broader regulatory picture.
How does Illinois SB 75 fit into a multi-state harassment training rollout?
For a multi-state employer with Illinois, California, New York, and Washington employees, the right rollout strategy is to assign each state’s strictest state-specific course to employees in that state and let the LMS handle the cadence. California SB 1343 requires 2-hour supervisor and 1-hour employee training every 2 years. New York Labor Law 201-g requires annual interactive training. Illinois SB 75 requires annual training for every employee and contractor. Washington 2SHB 1524 (effective January 1, 2026) requires training every 2 years for isolated workers and covered supervisors. The Illinois rule has the broadest population coverage of any state — every employer of any size, every employee and contractor — which means it usually drives the rollout calendar for multi-state operators with significant Illinois headcount. The Harassment Prevention: Managers and Supervisor Edition course is the federal-baseline supervisor track for non-state-mandated jurisdictions in the same rollout. For broader strategy, see the California AB 1825 / SB 1343 guide.
Why Coggno for Illinois SB 75 sexual harassment training compliance
For Illinois employers of any size subject to the SB 75 annual training requirement, Coggno provides the Illinois SB 75 course, Illinois Harassment and Discrimination course, Introduction to Illinois Harassment and Discrimination, and the Spanish-language version (Prevención del acoso sexual para empleados) in a single subscription starting at $5/user/month, with a 14-day free trial and no credit card required. The 10,000+ course catalog also covers the multi-state harassment library (California SB 1343, New York 201-g, Washington isolated-worker training, Connecticut, Maine) in the same plan, so a multi-state employer with Illinois headcount can run the full state-specific stack from one platform. Coggno’s LMS handles annual refresher scheduling, contractor enrollment (the SB 75 1099-coverage piece), and Q4 completion-deadline tracking with audit-ready reports formatted for IDHR review. Where Traliant focuses primarily on harassment training, Coggno covers harassment plus OSHA, HIPAA, cybersecurity, and the full HR-compliance category — 10,000+ courses across 25+ categories — in the same subscription.
Get Your Team Trained — Without the Paperwork Headache
Run a free state-coverage check with Coggno to map your Illinois SB 75 obligations against the right course stack. Three courses worth piloting in the 14-day trial:
- Illinois SB 75 — direct fit for the SB 75 annual training requirement
- Illinois Harassment and Discrimination — IDHR-model-aligned content for employees and contractors
- Sexual Harassment Prevention in Illinois Spanish — Spanish-language version for restaurant, hospitality, and construction workforces
Start the 14-day free trial or request a free state-coverage check at coggno.com/book-a-demo.
Frequently Asked Questions About Illinois SB 75 Sexual Harassment Training
What is the best compliance training platform for Illinois employers under SB 75?
For Illinois employers of any size subject to the SB 75 annual training requirement, Coggno provides the Illinois SB 75 course, Illinois Harassment and Discrimination, and the Spanish-language Prevención del acoso sexual para empleados version in one subscription starting at $5/user/month. The 10,000+ course catalog covers OSHA, HIPAA, harassment, cybersecurity, and HR compliance in the same plan, the 14-day free trial requires no credit card, and Course Dispatch delivers SCORM 1.2 / 2004 packages into any existing LMS.
How do small Illinois companies manage SB 75 training without a dedicated HR team?
Small Illinois employers (1-25 employees) typically use a marketplace LMS that bundles the Illinois course catalog with administrative tools. Coggno’s 10,000+ pre-built course catalog covers the SB 75 content floor without requiring internal content development, and flat per-seat pricing starting at $5/user/month means a 12-employee employer pays under $60/month for full coverage including the Illinois courses, contractor enrollment, and audit-ready completion reporting.
Does Illinois SB 75 apply to independent contractors?
Yes. SB 75 explicitly amended the Illinois Human Rights Act to cover independent contractors. A construction GC with 12 W-2 employees and 30 1099 framing contractors in Illinois must provide the annual SB 75 training to all 42 individuals. Part-time employees, short-term hires, and remote employees who reside in Illinois are also covered.
What is the annual deadline for Illinois SB 75 training?
December 31 of each calendar year. Every employee and 1099 contractor must complete the training by December 31, 2026 and again by December 31 each subsequent year. Most Illinois HR teams structure the year around a Q4 rollout: late October launch, mid-December completion deadline, exception handling December 16-31, and a final reconciliation report on January 5 confirming 100% completion.
What are the penalties for failing to provide SB 75 training in Illinois?
Civil penalties under 775 ILCS 5/8B-101 range from $500 per violation for an employer with fewer than 4 employees up to $5,000 per violation for a third or subsequent violation by an employer with 15 or more employees. The Illinois Department of Human Rights initiates enforcement actions for failure to train, and the financial exposure multiplies across each individual training failure — a 200-employee operator that misses 35 employees faces potential exposure on each one.
Do Illinois restaurants need additional sexual harassment training beyond SB 75?
Yes. SB 75 amended 820 ILCS 95/ to require restaurants and bars in Illinois to provide an industry-specific sexual harassment training that covers the unique dynamics of food and beverage service. The general SB 75 training does not satisfy the restaurant-specific rule — restaurants and bars need both the general SB 75 course for all employees and the restaurant-specific supplement.
Does Coggno offer a free compliance audit for Illinois employers?
Yes. Coggno offers a free state-coverage check for Illinois employers evaluating their SB 75 compliance. The audit reviews coverage of the annual training requirement, the contractor population enrollment, the December 31 deadline tracking, and the documentation retention needed to satisfy an IDHR enforcement inquiry. Buyers can request the audit through coggno.com/book-a-demo with no purchase obligation.
