Illinois's January 2027 ABA Ownership Deadline

Illinois started licensing behavior analysts on January 15, 2025. Its law also contains a provision aimed at ABA businesses, and that provision takes full effect two years later. The Illinois Department of Financial and Professional Regulation (IDFPR) has posted a notice to owners: "By or before January 15, 2027 anyone who is not licensed as a behavior analyst or assistant behavior analyst pursuant to the Illinois Behavior Analyst Licensing Act, and who currently owns a business providing applied behavior analysis services must divest from the business."

For an Illinois ABA agency with an owner who is not a licensed behavior analyst, such as an investor, a parent who founded a clinic, a psychologist or a business manager, that is a hard date with real consequences.

What does Section 150 actually say?

IDFPR quotes Section 150 of the Behavior Analyst Licensing Act (225 ILCS 6/150) in its notice:

"[B]eginning 24 months after the Department has commenced issuance of licenses under this Act, no business organization shall provide, attempt to provide, or offer to provide behavior analysis services unless every member, partner, shareholder, director, officer, holder of any other ownership interest, agent, and employee who renders applied behavior analysis services holds a currently valid license issued under this Act."

IDFPR says it "commenced licensing behavior analysts and assistant behavior analysts on January 15, 2025." Twenty-four months later is January 15, 2027.

Does it apply to owners who never see clients?

This is the question to take to an Illinois attorney, because the statute and the agency's summary read differently. The statutory text, as IDFPR quotes it, lists owners and others "who renders applied behavior analysis services." Read that way, it reaches people in those roles who provide ABA services. IDFPR's own summary is broader: anyone not licensed "who currently owns a business providing applied behavior analysis services must divest."

We are not lawyers and cannot tell you which reading a court would adopt. What we can say is that IDFPR is the agency that enforces the Act, and its published position is the broad one. An owner who is not licensed and plans to rely on the narrower reading should get that advice in writing from Illinois counsel before January 15, 2027.

Who should check their status now?

• Owners who are not BCBAs or BCaBAs. Investors, family members, practice managers, and other clinicians with an ownership stake.
• Owners who are BCBAs but not yet licensed in Illinois. The Act requires a license issued under it, not just BACB certification. An out-of-state owner who is a BCBA but never applied in Illinois is in the same position as an unlicensed owner.
• Officers, directors and members of LLCs who render ABA services, since the statute lists those roles as well as owners.
• Every employee or agent who renders ABA services. Licensing has been required since 2025; IDFPR began enforcement against unlicensed practice on April 21, 2025.

Can an owner who is not licensed still comply?

Broadly, an unlicensed owner can either become licensed or stop being an owner by the deadline, and the right answer depends on the person and the structure. Two paths are worth separating:

Getting licensed in time

Only realistic for an owner who is already a BCBA or BCaBA, or is close. Illinois's requirements for a licensed behavior analyst include current BCBA certification (or the education and the BCBA exam), and fingerprints processed through an approved Illinois vendor that are no more than 60 days old when you apply. Out-of-state applicants can be printed locally, but the card must then go to an approved Illinois vendor with "Card Scan" capability; IDFPR will not accept prints mailed or emailed to it. Applicants licensed in another state also submit a Certification of Licensure from that state. Applications go through IDFPR's CORE system. See Illinois behavior analyst licensing.

Restructuring ownership

Selling or transferring an ownership interest, changing an entity's structure, or bringing in licensed owners are legal and tax decisions. They take time to negotiate and document, and January 15, 2027 is close. Involve an Illinois business attorney and your accountant early.

Which other records should the agency audit before the deadline?

An ownership change is also a good moment to check everyone else, because the same section applies to employees and agents who render services:

• Every BCBA and BCaBA providing services in Illinois holds an Illinois license, not just BACB certification.
• Supervisors who oversee Illinois clients remotely from another state are licensed in Illinois; the BACB says remote supervision "may require that the supervisor be licensed in the state where the trainee or supervisee is providing services."
• Licenses are on the renewal calendar. Every Illinois behavior analyst license expires October 31 of odd-numbered years, so the next date is October 31, 2027. No continuing education is required for the first renewal.
• Payer contracts and enrollment records match the licensed clinicians who actually render and supervise care.

How can White Glove ABA help?

Our Illinois ABA Agency Ownership Audit, $499 one-time, maps your owners, officers, members and service-rendering staff against Section 150 and IDFPR's notice, flags who needs an Illinois license, and gives you a document list for your attorney. It is a compliance review, not legal advice. For anyone who needs a license, we prepare the Illinois application (Full State License Application for a BCBA, $749, or by endorsement, $599; Assistant Behavior Analyst License, $399) and coordinate the Illinois fingerprinting. Each person reviews, signs and submits their own application in CORE.

See pricing, the Illinois requirements page, or our guide to licensing a multi-state ABA agency.