Illinois Bans AI as Sole Basis for Teacher Evaluations, Mandates Human Judgment

Illinois has become the first state to draw a clear regulatory line on artificial intelligence in teacher evaluations, signing a law that bars administrators from using AI tools to write performance reviews. The bill, Senate Bill 2909, was signed by Governor JB Pritzker and takes effect immediately, according to the Illinois Senate Democrats. Its sponsor, State Sen. Christopher Belt (D-Swansea), said teachers should be judged on “actual observations and professional judgement, not by AI software.” The law stops short of a total ban, but it forces a fundamental shift: any use of AI in evaluations must be disclosed and overridable by human evaluators.

Senate Bill 2909 was enacted after passing both chambers of the Illinois General Assembly, with Belt leading the charge. The law explicitly prohibits school administrators from using AI tools to write teacher evaluations—but it does not ban AI for other administrative tasks such as scheduling, record-keeping, or student attendance tracking.

If an evaluator does use AI-assisted tools, the law requires them to identify the tool and its purpose and share that information with the teacher being evaluated. In practice, this means an AI-generated draft or suggestion can be consulted, but the final evaluation must be written and justified by a human.

AI law trackers describe SB 2909 as barring AI as the sole basis for teacher performance evaluation while allowing human oversight. This nuance is critical: it stops a school district from letting an algorithm decide a teacher’s rating, but it does not forbid AI as a supplementary aid, provided the teacher knows the system is being used.

The law is separate from another Illinois education AI measure, SB 416 / the Student Educational Technology Rights Act, which focuses on classroom AI use and grading—not teacher evaluations. That bill is still making its way through the legislature.

Teacher evaluations have long been a contentious topic in education reform. In recent years, several school districts experimented with automated systems to score classroom observations, analyze lesson plans, or even predict teacher effectiveness. However, concerns about bias, lack of context, and the potential for AI to misinterpret nuanced human interactions have grown.

The Illinois law directly addresses those concerns. By mandating that AI cannot be the sole basis for evaluation, the state is acknowledging that teaching is a deeply human profession that requires subjective, contextual judgment—something current AI models are ill-equipped to replicate.

Nationally, this move places Illinois ahead of federal guidance. The U.S. Department of Education has issued voluntary AI principles but has no binding rules on teacher evaluation. Meanwhile, states like Texas and California have introduced bills with varying levels of restriction, but none have yet become law. Illinois’s immediate-effective-date approach suggests urgency: lawmakers wanted to prevent districts from rolling out AI evaluation systems before guardrails were in place.

For teachers’ unions, this is a significant victory. They have long warned that AI evaluation tools could be used to justify firing or penalizing educators without proper human review. The Illinois law gives union leaders a concrete legal lever to demand transparency in any AI-assisted evaluations that do occur.

Edtech companies that sell AI-powered evaluation tools now face a tight regulatory environment in Illinois. If their product is designed to generate final written evaluations without meaningful human input, it will violate state law. Vendors must pivot to human-in-the-loop models—tools that provide analysis or suggestions but require a licensed evaluator to craft the final narrative and rating.

The disclosure requirement also adds compliance costs: companies must build in mechanisms to log which AI tools were used, for what purpose, and how that information is shared with the teacher. For startups accustomed to lean operations, this could mean hiring compliance officers or legal counsel to navigate state-specific regulations.

Larger players, like PowerSchool or Frontline Education, already offer evaluation software with human-review workflows. Those companies may see an opportunity to market their products as “Illinois-compliant” out of the box. But smaller competitors that rely on fully automated scoring could be shut out of the Illinois market entirely.

The law does not ban AI for administrative tasks, so tools used for scheduling, data entry, or student analytics remain unaffected. Companies focused on those areas can continue business as usual—for now.

The Illinois experiment will be closely watched by other state legislatures. Similar bills are pending in New York, Colorado, and Massachusetts. If Illinois’s law proves effective—reducing complaints about unfair evaluations while preserving administrative efficiency—it could become a template for national policy.

Separately, SB 416 (Student Educational Technology Rights Act) is still alive in Illinois. That bill would regulate AI use in grading and classroom instruction, potentially creating a broader regulatory framework. Tech companies serving Illinois schools should track the progress of that measure closely.

For now, Illinois has made a clear statement: AI can assist in evaluating teachers, but it cannot write the final report card. The question is whether other states will follow suit—or whether the EdTech industry will voluntarily adopt transparency standards before more legislatures act.