Illinois Expands Faith’s Law: What Schools Need to Know About New Grooming and Sexual Misconduct Provisions

The State of Illinois continues to build on Faith’s Law. On August 10, 2026, Governor Pritzker signed Public Act 104-0831 (House Bill 4534). The new law makes several changes to the School Code and the Abused and Neglected Child Reporting Act with one shared goal: helping schools spot and stop grooming and other boundary violations. It takes effect on January 1, 2027.

Faith’s Law (Public Act 102-0676, later expanded by Public Act 102-0702) requires schools to adopt an employee code of professional conduct, complete employment history reviews before hiring, and notify students and parents of alleged sexual misconduct. The new law adjusts several of these requirements and makes a related change to the Abused and Neglected Child Reporting Act (ANCRA). Below, we summarize each change and what it means for schools.

1. ANCRA Now Covers a Broader Range of Grooming Behavior

Until now, grooming counted as child abuse under ANCRA only if it amounted to the crime of grooming under the Criminal Code (720 ILCS 5/11-25). The new law replaces that reference with a broader standard that does not depend on proving a crime.

Under the new definition, a child is abused if a covered adult, including school personnel, engages in a “pattern of conduct or communications directed toward such child, meaning 2 or more instances of conduct or communication,” that “a reasonable person would understand as intended to groom, seduce, solicit, lure, or entice the child” to commit a sex offense or engage in sexual misconduct. (325 ILCS 5/3.)

“Sexual misconduct” here means any communication or physical activity meant to establish a romantic or sexual relationship with the child. Examples include:

• sexual or romantic invitations;
• dating or asking a child on a date;
• sexualized or romantic dialog; and
• sexually suggestive comments.

This definition now  incorporates the definition of “sexual misconduct” schools already use under Faith’s Law. (105 ILCS 5/22-85.5(c).)

What This Means for Schools

School employees are mandated reporters (325 ILCS 5/4), and ANCRA expressly includes educational personnel among the people “responsible for the child’s welfare” (325 ILCS 5/3). As a result, this amendment makes clear that a school employee who has reasonable cause to believe that a staff member has engaged in a pattern of grooming behavior (two or more instances) must report it to the Department of Children and Family Services (DCFS), and DCFS may investigate it as abuse, even if the conduct would not support a criminal grooming charge. Schools should update their mandated reporter and Faith’s Law training so staff can recognize these patterns and know when to report.

2. More Information Must Be Posted Online and in Handbooks

Schools already must post their employee code of professional conduct policy on their website and include it in handbooks. Under the new law, schools must also post and include:

• the guidelines the school has set for transporting students, taking or possessing photos or videos of students, and meeting with or contacting students outside an employee’s professional role; and
• all available ways to report staff-student boundary violations, both within the school and to outside agencies.

These materials must appear in every staff, student, and parent handbook. The prior version of the law said staff, student, or parent handbook. The law also removes language that limited the handbook requirement to nonsectarian nonpublic schools, so it now applies to religious schools as well. (105 ILCS 5/22-85.5(e).)

What This Means for Schools

Schools should review their policy and handbooks to make sure the boundary guidelines and reporting options are clearly spelled out. They should then update their website and every handbook before January 1, 2027.

3. Regional Offices of Education Can Help with Substitute Teacher Employment History Reviews

Faith’s Law requires an employment history review before a school hires a substitute or adds a substitute to its approved list, and again each time the substitute joins another school’s list. (105 ILCS 5/22-94(i).  Under the new law, for licensed substitute teachers seeking work in more than one school district, the regional office of education (ROE) or intermediate service center (ISC) may collect the required employment history information and, at the substitute’s request, share it with districts. (105 ILCS 5/22-94(c)(4), (i)(1.5).) Some key points to note:

• Limited role. The ROE or ISC only collects and shares records. It does not decide whether a substitute is fit to hire, and the district still completes the rest of the review unless it agrees otherwise with the ROE or ISC.
• One review, many districts. The review stays valid as long as the substitute keeps working for a district in the ROE’s or ISC’s region or stays on its approved substitute list.
• The ROE or ISC must promptly share records with the hiring district and pass along any updated information it later receives.
• Liability protection. ROEs, ISCs, and districts that share records through this process are protected from liability unless the information is knowingly false. (105 ILCS 5/22-94(e), (i)(1.5).)

What This Means for Schools

ROE participation is optional. Districts should ask their ROE or ISC whether they plan to offer this service and, if so, how records will be shared.

4. Schools Must Give Parents 5-Day Notice Before Beginning Erin’s Law Instruction

The new law allows parents and guardians of students in pre-K through 8th grade to opt their child out of sexual abuse prevention instruction under Erin’s Law by submitting a written objection. Opting out cannot affect the student’s academic standing. Schools must give parents and guardians at least five days’ written notice before the instruction begins. (105 ILCS 5/27-215(e).)

Schools may recall a similar opt-out right. That language previously appeared in the School Code but was removed by a recent amendment. The new law restores it.

What This Means for Schools

Schools must send their notice to parents on time, at least five days before Erin’s Law instruction begins, and may want to include a link to an opt-out form in the notice. Teachers and administrators should also closely monitor email and other communications for parent objections so that students who have opted out are not included in the instruction.

5. Fewer current-employer contacts.

For an employment history review, applicants now must list their current employer only if they work with children or students in that job. (105 ILCS 5/22-94(c)(3)(A)(i).)

Looking Ahead

Before the new law takes effect on January 1, 2027, schools should:

• post the boundary guidelines and reporting options on their website and add them to all staff, student, and parent handbooks;
• update mandated reporter and Faith’s Law training to address the new grooming standard;
• update employment history review procedures for the current-employer change;
• talk with their school district’s ROE or ISC about substitute teacher reviews; and
• send the required five-day notice before Erin’s Law instruction in pre-K through 8th grade (consider linking an opt-out form) and set up a process to track parent objections.

If you have questions about Public Act 104-0831 or need help updating your policies, handbooks, or training, please contact the authors of this alert or any Franczek attorney.