is the one breached, with notification duties running to both the FTC and, under the Illinois Personal Information Protection Act, the state Attorney General. Recording sales transactions raises further traps under Illinois’s two-party-consent eavesdropping law and the Biometric Information Privacy Act, both of which carry severe penalties. Employment and Structure Illinois car dealerships operate in one of the most heavily regulated employment environments in the country, and 2026 alone brought sweeping changes that make ongoing vigilance essential rather than optional. Amendments to the Illinois Workplace Transparency Act now bar confidentiality provisions in agreements signed or modified after Jan. 1, 2026, from restricting employees’ ability to engage in “concerted activities” like collective bargaining, while broadening the definition of unlawful employment practice to cover wage, hour, and other workplace issues beyond just harassment and discrimination. New AI-related amendments to the Illinois Human Rights Act also prohibit employers from using artificial intelligence that discriminates against protected classes in employment decisions, including a specific ban on using zip codes as a proxy for race or national origin — a real risk for dealerships using AI-driven applicant screening or scheduling tools. On top of that, dealerships must track new leave obligations like the Family Neonatal Intensive Care Leave Act, effective June 1, 2026, which requires unpaid leave for employees whose child is in the NICU, plus updated VESSA and nursing mothers’ protections. Given the rapid pace of change, Illinois dealerships need regularly updated handbooks, manager training, and compliance reviews to avoid the steep monetary penalties and legal exposure tied to falling behind. The Through-Line Responsibility does not travel with delegation — outsourcing shifts work, never liability. Documentation is the mechanism by which legal rights become usable; franchise protections, refusal-of-service defenses, and breach responses all depend on documents and records created before they were needed. Counsel belongs at the beginning of decisions, not the end. The rules will keep changing; several already have. The dealership as a regulated institution must stay ahead of change. © 2026 Law Office of Julie A. Cardosi, P.C. Julie A. Cardosi is an Illinois Attorney and Principal of the private firm, Law Office of Julie A. Cardosi, P.C., of Springfield, Illinois. She has practiced law for over 40 years and represents the business interests of franchised motor vehicle dealers throughout Illinois. Formerly in-house staff General Counsel for the Illinois Automobile Dealers Association, she concentrates her private practice in the areas of dealership compliance matters, franchise law, transfers of ownership, mergers and acquisitions, commercial real estate transfers, dealership employment and other areas impacting day-to-day dealership operations. She also served as Illinois Assistant Attorney General and Deputy Chief of the Consumer Fraud Bureau of the Attorney General’s Office, where she was the primary author of the Illinois Motor Vehicle Advertising Regulations. The material discussed in this article is for general information only and is not intended as legal advice and should not be acted upon as such. Dealers should consult their own private legal counsel for application to their specific circumstances. For more information, Julie can be reached at jcardosi@autocounsel.com or at (217) 787-9782. 13 ILLINOIS AUTOMOBILE DEALER NEWS
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