Illinois Frontier AI Safety Act Requires Annual Third-Party Audits of Largest AI Developers — Effective January 2027

Illinois Governor J.B. Pritzker signed S.B. 315 — the Artificial Intelligence Safety Measures Act — into law on July 6, 2026, creating the first US state law requiring annual independent third-party audits of frontier AI model safety practices. The Act targets the largest frontier AI developers (over $500 million in annual revenue, developing models above a specified computational power threshold) and requires them to meet baseline user protection requirements and additional safeguards for minors. While the Act is primarily directed at AI developers rather than deployers, it has downstream implications for law firms: platforms built on top of frontier models from Illinois-headquartered or Illinois-operating developers will carry an annual audit cycle that generates compliance documentation law firms can use in their own governance processes. The Act takes effect January 1, 2027, and the JD Supra AI Washington Report from August 10 identifies it as the strongest state-level frontier AI safety requirement in the country to date — a benchmark that other states will reference in their own legislative drafts.