Chicago Sexual Harassment Training Requirements for Employers

Chicago’s sexual harassment training requirements apply to every employer with even one worker in the city and run on a July 1 to June 30 cycle. Non-supervisory employees need two hours of training each year: one hour of sexual harassment prevention plus one hour of bystander intervention. Supervisors and managers need three: two hours of prevention plus the same bystander hour. Training sits alongside a written policy, a posted notice, and recordkeeping, and missing any of these carries fines of $500 to $1,000 per offense.¹

Which Employers and Workers Are Covered

The ordinance reaches any business that keeps a facility inside Chicago or employs at least one person working in the city. There is no headcount floor. A company with a single Chicago employee owes the same obligations as a large corporation.¹

An “employee” is anyone engaged to work within Chicago’s geographic boundaries. That includes a remote worker whose home is in the city even when the employer’s headquarters sits in another state. The training obligation also follows the reporting line: managers and supervisors of Chicago-based employees have to be trained even if those managers themselves work outside the city.¹

Independent contractors sit in a gray area. The ordinance protects them from harassment and holds employers responsible if a contractor harasses an employee or another contractor. The annual training mandate, though, is written for “employees,” and the city’s own training materials distinguish employees from nonemployees such as independent contractors and gig workers. Employers who regularly use contractors on-site often train them anyway, but the strict legal duty runs to employees.²

Annual Training Hours and the July 1 Cycle

Three separate training components make up the annual requirement:

One hour of sexual harassment prevention training for all employees each year.
Two hours of sexual harassment prevention training for supervisors and managers each year.
One hour of bystander intervention training for everyone, employees and supervisors alike.

The bystander hour is a standalone requirement. It cannot be folded into the general prevention module to save time. Added up, a non-supervisor completes two hours a year and a supervisor completes three.¹

The training year runs from July 1 through June 30. Every employee has to finish the required hours inside that window. Training everyone in January is fine, but the following July resets the clock. An employer cannot skip the next cycle on the theory that the last session was less than twelve months ago.¹

What the Training Must Cover

Employers can build their own curriculum or use the model program Illinois publishes under the Illinois Human Rights Act, but whatever they use has to meet or exceed the state’s minimum content standards.³ Those standards require the training to cover:

An explanation of what sexual harassment is under the law.
Examples of conduct that qualifies as unlawful harassment.
A summary of federal and state legal protections, including the remedies available to someone who experiences harassment.
A summary of employer responsibilities for preventing, investigating, and correcting harassment.

Restaurants and bars carry an extra layer. The state requires supplemental training on industry-specific scenarios and manager liability.⁴

The bystander module teaches safe, constructive ways to step in when someone witnesses harassment: recognizing the situation, deciding to act, and choosing an approach that does not escalate things.

Language matters too. If a significant portion of the workforce has limited English proficiency, the employer has to provide materials in those employees’ primary languages. The Commission on Human Relations publishes free, downloadable model modules. Manager-level training is available in English, Spanish, Polish, Hindi, and Chinese. Employee and bystander modules are available in English and Spanish.⁵ The city treats these as starting templates that employers should expand and tailor to their own workplace, not as a plug-and-play shortcut that satisfies the hour requirement on its own.

Written Policy and Poster

Training is only part of the package. Every Chicago employer must maintain a written sexual harassment policy that includes:³

A statement that sexual harassment is illegal in Chicago.
The ordinance’s definition of sexual harassment.
A requirement that all employees complete annual sexual harassment prevention and bystander intervention training, with the hour minimums for staff and supervisors spelled out.
Concrete examples of behavior that qualifies as sexual harassment.
Instructions for reporting an allegation, including confidential options through an internal complaint form, a manager, human resources, or another internal channel.
Information about legal resources, including government agencies, available to employees who experience harassment.
A statement that retaliation for reporting harassment is illegal in Chicago.

The written policy has to be handed to every new hire in that person’s primary language during the first calendar week of employment. Employers who wait until an orientation session two weeks in are already out of compliance.³

At least one poster on the prohibition against sexual harassment must be displayed where employees commonly gather. The ordinance requires at least one poster in English and one in Spanish. The Commission on Human Relations designs the posters, so employers do not have to build their own.⁷

Recordkeeping

After each training session, the employer needs to document what happened and who attended. At a minimum, records should capture the date, the name of every participant, and the training provider or materials used. Retain those records for at least five years, or for the duration of any pending complaint, investigation, or lawsuit if that period is longer.

Keep them somewhere central and accessible. When the Commission on Human Relations opens an investigation or runs an audit, training records are among the first documents requested. An employer who actually trained everyone but cannot prove it stands in the same position as one who never trained at all.6City of Chicago. Sexual Harassment

Fines for Missing the Requirements

Penalties are tiered by the type of violation:

Failing to post the required notice, conduct annual training, or maintain a written policy: $500 to $1,000 per offense.¹
Other violations of Chapter 6-10: $100 to $500 per offense, with each day of continued violation treated as a separate offense.³

“Per offense” is where the math gets painful. An employer with 50 untrained employees does not face a single $500 fine; each untrained employee can count as a separate violation. Compliance costs look small next to that exposure.

How This Compares to Illinois State Law

Illinois already requires every employer in the state to provide annual sexual harassment prevention training that meets minimum standards under the Illinois Human Rights Act. The state does not set a specific hour requirement for most employers and does not require bystander intervention training. Employers who violate the state rule get a notice to comply within 30 days before any civil penalty attaches.⁸

Chicago stacks on top of that. The city adds the one-hour minimum for employees, the two-hour minimum for managers, the separate bystander intervention hour, the written policy mandate, the poster requirement, and steeper fines with no grace period. A Chicago employer who follows only the state rules is not in compliance with the city. Both sets of obligations apply at the same time, and the Commission on Human Relations enforces the city’s independently.

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City of Chicago. Sexual Harassment
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City of Chicago. Sexual Harassment Prevention Training
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American Legal Publishing. Municipal Code of Chicago 6-10-040 Sexual Harassment
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Illinois Department of Human Rights. FAQ for Sexual Harassment Prevention Training
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City of Chicago. Sexual Harassment Training Materials
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American Legal Publishing. Municipal Code of Chicago 6-10-040 Sexual Harassment

Recordkeeping
After each training session, the employer needs to document what happened and who attended. At a minimum, records should capture the date, the name of every participant, and the training provider or materials used. Retain those records for at least five years, or for the duration of any pending complaint, investigation, or lawsuit if that period is longer.

Keep them somewhere central and accessible. When the Commission on Human Relations opens an investigation or runs an audit, training records are among the first documents requested. An employer who actually trained everyone but cannot prove it stands in the same position as one who never trained at all.6City of Chicago. Sexual Harassment
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Illinois Department of Human Rights. Minimum Sexual Harassment Prevention Training Standards for All Employers