2026 Pub. 16 Issue 1

Julie Cardosi, Esq. Law Office of Julie A. Cardosi, P.C. A​rtificial intelligence (AI) has moved from a futuristic concept to a daily operational tool in automotive retail. Dealerships now rely on AI to automate follow‑up, personalize online shopping, optimize inventory and streamline service scheduling. But in Illinois, the rapid adoption of AI intersects with one of the most aggressive state regulatory frameworks in the country. As of Jan. 1, 2026, new legal requirements affect how dealerships can use AI in employment‑related decisions — and many retail tools overlap with those rules. For Illinois dealers, the challenge is clear: embrace AI’s advantages while staying compliant. This article breaks down how dealerships are using AI in 2026 and what Illinois law requires as these tools are integrated into dealership operations. How Dealerships Are Using AI in 2026 AI is now embedded in nearly every stage of the dealership experience. The most common applications include: Lead Scoring and Routing: AI evaluates customer behavior, online activity and engagement to prioritize leads. Automated Follow‑Up: Chatbots and CRM automations respond instantly to inquiries and maintain consistent communication. Personalized Digital Retailing: AI tailors vehicle recommendations, payment options and incentives based on customer profiles. Inventory Optimization: Predictive analytics help dealers stock the right vehicles at the right time. Service‑Department Efficiency: AI forecasts repair needs, improves scheduling and boosts retention. These tools help dealerships operate more efficiently and deliver a smoother customer experience. But they also raise legal questions when AI influences employment decisions or interacts with sensitive consumer data. Illinois’ New AI Rules: What Changed in 2026 The Illinois Human Rights Act was amended to regulate how employers use AI in hiring, promotion and other employment‑related decisions. These rules apply to all Illinois employers, including auto dealerships, and took effect Jan. 1, 2026. NOTICE REQUIREMENTS Dealerships must notify job applicants and employees when AI is used “to influence or facilitate” decisions such as hiring, promotion, scheduling or discipline. This includes tools that screen résumés, score applicants, or recommend which employees receive additional training or hours. PROHIBITION ON DISCRIMINATORY AI USE Illinois prohibits the use of AI systems that result in discrimination based on protected characteristics — and uniquely, zip code. Because zip code can correlate with race, income and other protected traits, Illinois treats it as a potential proxy for discrimination. BROAD SCOPE OF COVERAGE The law applies to: • Recruitment • Hiring and Termination • Promotion • Training • Scheduling • Discipline If AI influences any of these decisions, the dealership must comply with the new requirements. COUNSELOR’S CORNER What Illinois Auto Dealers Should Know AI‑Driven Dealership Retailing 2026 16 ILLINOIS AUTOMOBILE DEALER NEWS

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