We respectfully urge the Governor to veto SB 315, primarily due to the unworkable third-party AI Audit requirement. This bill demands that frontier AI developers submit to independent audits by 2028, but the auditing standards, certifying bodies and compliance methodologies it requires simply do not exist. Rather than protecting consumers, this impossible mandate will curb innovation, drive investment and talent out of Illinois and expose companies to millions in penalties for failing to comply with requirements that are impossible to meet.
NetChoice Veto Request Letter to Gov. Pritzker on Illinois SB 315, the Artificial Intelligence Safety Measures Act
June 2, 2026
The Honorable JB Pritzker
Governor of Illinois
Office of the Governor
207 State House
Springfield, Illinois 62706
Dear Governor Pritzker:
On behalf of NetChoice, a trade association working to make the Internet safe for free enterprise and free expression, we write to respectfully urge you to veto Senate Bill 315, or, should you find merit in its remaining provisions, to issue an amendatory veto striking Section 10(d).
Proponents have characterized this legislation as aligned with California and New York law, but that framing is misleading. Senate Bill 315 goes materially further — and in doing so, introduces a critically flawed mandatory third-party audit requirement that creates compliance obligations no regulated entity can realistically meet. The timeline is unworkable, the obligations are undefined and the auditing profession lacks the infrastructure to fulfill them. This bill does not raise the bar; it sets an impossible one.
SB 315’s Fundamental Flaw: Mandating Nonexistent Infrastructure
Section 10(d) of the bill mandates that beginning January 1, 2028—less than two years away—large frontier developers must annually retain third parties to perform independent audits of compliance. These audits must be conducted consistently with generally accepted auditing standards and best practices by entities possessing ‘demonstrated competence to perform the audit, including experience employing or contracting with individuals who possess technical expertise in the safety of frontier models.’
While it is theoretically possible that such entities could eventually emerge, the bill does not create any pathway or timeline for developing the necessary infrastructure. This is not a complaint that the market needs time to develop—it is a more fundamental problem: the statute mandates compliance with audit requirements that have no defined methodology, contain no standards for what audits should assess, include no framework for certifying auditors and contemplate no approach for how generally accepted auditing standards for frontier model safety would be developed.
Currently, no credible or standardized ecosystem exists to conduct the type of independent audits envisioned under the legislation. There are no broadly recognized certification standards, no licensing structures and no established oversight mechanisms for entities seeking to perform AI safety compliance audits. The bill contains no framework for certifying qualified auditors, establishes no standards for what audits should assess and does not create a methodology for evaluating compliance. The statute requires that audits be conducted according to ‘generally accepted auditing standards and best practices,’ yet no such standards currently exist for frontier model safety. These standards do not exist because they have not been developed by standards-setting organizations, regulatory bodies or the industry itself. Companies cannot comply with auditing standards that do not yet exist. They cannot hire auditors to perform audits that have no defined methodology. They cannot provide evidence of compliance with requirements that have not been specified.
The bill creates a scenario where large frontier developers must make an impossible choice: either attempt to hire non-existent auditors to perform undefined audits against non-existent standards, or risk civil penalties up to three million dollars for noncompliance with an unattainable requirement. This serves no legitimate consumer protection purpose and instead creates legal jeopardy that will chill investment and development in Illinois and potentially across the country.
SB 315’s Auditing Requirement Will Chill Innovation
The audit requirements create a broader chilling effect on frontier AI innovation. Frontier AI development requires substantial capital investment in research, talent and computational resources. Each dollar spent on compliance activities, whether it is hiring external auditors, conducting internal assessments or managing regulatory affairs, is a dollar not spent on advancing AI capabilities and safety research. For companies developing frontier models in Illinois, the undefined and potentially expensive audit requirements create additional cost burdens that competitors in jurisdictions with clearer standards do not face.
Venture capital and institutional investors evaluate opportunities based on regulatory clarity and predictability. When considering funding a frontier AI company in Illinois, investors must factor in unknown compliance costs, undefined audit standards and penalties for non-compliance. This regulatory uncertainty creates a significant discount on expected returns, making Illinois a less attractive location for frontier AI development. Startups and smaller companies face disproportionate harm from compliance burdens that large incumbents can more easily absorb. Top researchers will gravitate toward opportunities in jurisdictions with greater regulatory certainty. If Illinois imposes uncertain, expensive compliance requirements while other states develop clear frameworks or impose none, frontier AI development will move to more hospitable jurisdictions—representing a lost opportunity for Illinois to compete for high-value technology jobs and economic growth in a critical emerging industry.
Again, NetChoice respectfully urges you to veto SB 315 outright or, should you find merit in its remaining provisions, to issue an amendatory veto striking Section 10(d) in its entirety. As always, we offer ourselves as a resource to discuss any of these issues with you in further detail, and we appreciate the opportunity to provide you with our thoughts on this important matter (The views of NetChoice expressed here do not necessarily represent the views of NetChoice members.).
Sincerely,
Amy Bos
Vice President of Government Affairs, NetChoice
NetChoice is a trade association that works to make the internet safe for free enterprise and free expression.