Illinois Mandates Independent Third-Party Audits for Large Frontier AI Developers
Large AI frontier model developers with annual gross revenues exceeding $500 million must prepare for Illinois' 2028 mandate requiring independent third-party audits of their AI risk management frameworks, marking a shift from self-reported to verified AI compliance.
Illinois has enacted the Artificial Intelligence Safety Measures Act (AISMA), a first-of-its-kind U.S. state AI regulation targeting frontier models trained with more than 10^26 floating-point operations, with core obligations applying to large frontier developers with over $500 million in annual gross revenue. Unlike prior U.S. and global AI rules focused on internal documentation and self-reported risk disclosures, AISMA mandates independent third-party verification of developers’ required Frontier AI Frameworks, plus quarterly reporting to state regulators and public transparency disclosures for new or modified frontier models. Covered developers should begin mapping existing AI risk processes to AISMA requirements, identify qualified independent auditors, and build compliance timelines ahead of the January 1, 2028 effective date.