State law covering ESAs in housing775 ILCS 5/3-104 — illinois human rights act — housing accommodation dutyYes
Effect of HUD's May 2026 changeState-law route is independent of HUD enforcementLimited
Minimum client–provider relationshipNo statutory waiting period in IllinoisNone
Pet fees and deposits for an approved ESAAddressed by state law, independently of HUDState law
Penalty for false documentationNo ESA-specific penalty statute; general fraud and misrepresentation law still appliesGeneral law
Public access rights for ESAsIn Illinois or any state — that is a trained-service-animal right under the ADANone
Where a complaint goesIllinois Department of Human RightsIDHR