Chicago Harassment Training Requirements: Hours, Deadline, and Fines

Chicago’s harassment training requirements apply to every employer with staff working in the city and call for annual sexual harassment prevention training plus a separate hour of bystander intervention training for each employee, on a January 1 through December 31 cycle. The rules sit in Chicago Municipal Code 6-10-040, took effect July 1, 2022, and carry fines of $500 to $1,000 for each day a violation continues.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment Training is only part of the obligation. Employers also need a written policy, a posted notice, and five years of records to prove they did what the ordinance requires.

Which Employers Are Covered

There is no minimum headcount. A two-person office and a 10,000-employee corporation face the same rules, and the ordinance covers full-time, part-time, and seasonal workers alike.2City of Chicago. Sexual Harassment

Remote staff count. An employee who works from home but reports to a manager or office located in Chicago is covered. The reverse also applies: a supervisor based outside the city who oversees Chicago-based employees has to complete the supervisor-level training.2City of Chicago. Sexual Harassment Independent contractors are a boundary worth noting: the ordinance does not require employers to train them, even though the city’s own training module references them.3FordHarrison. Chicago Employers: Notable Amendments to Chicago’s Sexual Harassment Ordinance

Employers are also liable for harassment committed by nonemployees or nonsupervisory staff once management knows about the conduct and fails to take reasonable corrective steps.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment

Training Hours by Role

The annual time commitment depends on the person’s role:

  • All employees: at least one hour of sexual harassment prevention training plus one hour of bystander intervention training.
  • Managers and supervisors: at least two hours of sexual harassment prevention training plus one hour of bystander intervention training.

A frontline employee needs two total hours each year. A supervisor needs three.2City of Chicago. Sexual Harassment

The Annual Deadline

The training cycle runs on the calendar year, January 1 through December 31. New hires should be trained as soon as possible after their start date rather than at year-end, because the employer is liable for a new employee’s conduct from day one.4Illinois Department of Human Rights. FAQ for Sexual Harassment Prevention Training

Why Illinois State Training Alone Is Not Enough

The Illinois Human Rights Act also requires annual sexual harassment prevention training for every employee working in the state.5Illinois Department of Human Rights. Training Standards for All Employers, Sexual Harassment Prevention The state’s model training satisfies Chicago’s one-hour prevention requirement for general staff, but it does not cover the rest of what Chicago demands. After completing the state program, Chicago employers still owe:

  • An additional hour of sexual harassment prevention training for supervisors and managers, bringing their prevention total to two hours.
  • An hour of bystander intervention training for every employee, including supervisors.

The city’s website is explicit that the Illinois model training alone does not fully satisfy Chicago’s law.2City of Chicago. Sexual Harassment Assuming statewide compliance is enough leaves a gap that accrues daily fines.

What the Prevention Training Must Cover

At a minimum, the sexual harassment prevention curriculum has to:

  • Define sexual harassment as the ordinance describes it, including unwelcome sexual advances, requests for sexual favors, and other conduct of a sexual nature that interferes with someone’s work or creates a hostile environment.
  • Provide concrete examples of conduct that crosses the line.
  • Explain the legal remedies available to victims, including how to file a complaint with the Chicago Commission on Human Relations.
  • Summarize employer responsibilities for preventing, investigating, and correcting harassment.

Employers can build their own program or use the city’s free templates, available in English, Spanish, Polish, Simplified Chinese, Arabic, and Hindi.2City of Chicago. Sexual Harassment A custom program must meet or exceed the minimum standards set by the Illinois Human Rights Act.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment

The Separate Bystander Intervention Hour

The one-hour bystander training is a distinct requirement, not a component of the prevention hour. Every employee, supervisors included, has to complete it each year.2City of Chicago. Sexual Harassment The city’s model bystander curriculum covers techniques for safely intervening in real time, de-escalation strategies, and ways to support the person being targeted.6City of Chicago. Bystander Intervention Model Training The materials are designed to be customized to fit each workplace.

Written Policy and Poster

Every Chicago employer must maintain a written sexual harassment policy and give it to each new hire in the employee’s primary language within the first calendar week of employment.2City of Chicago. Sexual Harassment The policy has to include:

  • The ordinance’s definition of sexual harassment.
  • Examples of prohibited conduct.
  • Details on legal services and government resources available to victims.
  • Internal reporting procedures and contact information.
  • A statement that retaliation for reporting sexual harassment is illegal in Chicago.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment

The anti-retaliation line is easy to overlook. Leaving it out of an otherwise thorough policy still counts as a violation.

A poster summarizing the ordinance’s protections and the complaint process must be displayed in a visible, accessible location. The Chicago Commission on Human Relations offers downloadable versions on its website.2City of Chicago. Sexual Harassment

Records You Have to Keep for Five Years

Employers must keep records of the written policy and of all training provided to each employee for at least five years, or for the duration of any pending complaint, lawsuit, or investigation, whichever is longer.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment Records should include the names of employees who completed each training, the dates of the sessions, and copies of the materials used.

Failing to keep those records is worse than a paperwork problem. If an employer cannot produce them, the ordinance presumes a violation of the training requirements. That presumption can only be rebutted with clear and convincing evidence.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment Training that happened but was never documented is treated as if it never happened.

Fines for Noncompliance

Missing training, an inadequate written policy, or a missing poster each carry a fine of $500 to $1,000 per offense, and every day the violation continues counts as a separate offense.1Chicago Municipal Code. Municipal Code of Chicago 6-10-040 – Sexual Harassment The daily accrual is where the real financial exposure sits. An employer that ignores the requirement for three months could face tens of thousands of dollars in accumulated fines before anyone files a complaint. These fines apply to the training, policy, and posting rules themselves; being found liable for actual harassment brings additional consequences through the Chicago Commission on Human Relations.