Where the law has caught up — and where it hasn't.

Illinois' WOPR Act (HB 1806, Public Act 104-0054) has been in effect since August 1, 2025 — it bars AI systems from standing in for a licensed clinician in therapy or psychotherapy, with civil penalties up to $10,000 per violation enforced by the Department of Financial and Professional Regulation.

• Illinois law now draws a clear line: an AI system cannot act as a therapist or provide psychotherapy to Illinois residents on its own — a licensed professional must be directly involved. Companion platforms that position themselves as emotional support or mental-health tools for Illinois users fall within the functional reach of this rule when they operate without that licensed oversight. The rule is about the role AI plays, not just how it is labeled. An app that conducts therapeutic conversations, makes mental-health recommendations, or substitutes for clinical judgment — regardless of what it calls itself — is the target of this statute. Civil penalties are assessed per violation after a DFPR hearing, so enforcement is complaint- and investigation-driven rather than automatic. Families in Illinois can file a complaint with DFPR if they believe a platform is operating outside these bounds.

• Read the full enrolled text of Public Act 104-0054 on the Illinois General Assembly site to see the exact definitions of 'therapy,' 'psychotherapy,' 'licensed professional,' and 'permitted use of artificial intelligence' — those definitions set the practical boundaries of what is covered. If you want to know whether a specific app or platform has been subject to DFPR action under this law, the Illinois Department of Financial and Professional Regulation publishes enforcement orders and disciplinary actions on its website at idfpr.illinois.gov.