The Illinois junk fee ban changes a simple, high-stakes question for every business in the state: is the price a customer sees the price the customer actually pays? Governor JB Pritzker signed the Junk Fee Ban Act on June 25, 2026, and it takes effect January 1, 2027. If your advertised price hides mandatory charges that show up later, you have roughly six months to fix your pricing before the rules apply.
This is not just a problem for hotel chains and ticket platforms. Restaurants, retailers, event companies, online sellers, salons, gyms, delivery services, and subscription businesses can all get caught when a mandatory charge appears too late in the customer journey.
The legal risk is only half the story. The bigger business risk is trust. Customers dislike surprise charges, and regulators dislike them too. When your website, menu, invoice, point-of-sale system, proposal, and checkout page each tell a slightly different pricing story, you have built a compliance problem into your sales process.
This article explains what the new law requires, where businesses get exposed, how a scoped pricing-flow audit works, and the red flags that should make owners nervous before the deadline becomes a scramble.
- What the Illinois junk fee ban requires
- Where businesses get exposed
- A scoped pricing-flow audit
- Who is affected by the new law
- A staged path beats rebuilding twice
- Red flags that should make owners nervous
- Frequently Asked Questions
- Next Steps
What the Illinois junk fee ban requires
At its core, the Illinois junk fee ban requires all-in pricing. The advertised price must reflect the total amount the customer has to pay, with no surprise mandatory fees added at the end. The law targets the gap between the sticker and the checkout total.
According to the Governor’s office and the Illinois General Assembly bill page (SB1486), the Junk Fee Ban Act addresses several common practices.
- Businesses must disclose the final, all-in price upfront rather than tacking on mandatory fees later.
- Service, processing, and convenience fees, surcharges, and mandatory gratuities generally cannot be hidden from the advertised price.
- Lodging and short-term rental businesses cannot add undisclosed “resort fees.”
- Food delivery and rideshare apps must itemize the price of goods and fees before a consumer checks out.
The practical message is straightforward. If a charge is mandatory, it belongs in the headline price or it must be disclosed clearly and early, not revealed as a surprise on the final screen.
The federal layer: the FTC rule on fees
Illinois is not acting alone. The FTC Rule on Unfair or Deceptive Fees took effect May 12, 2025. That federal rule applies to live-event tickets and short-term lodging, and it requires businesses to disclose the total price clearly, conspicuously, and prominently before prompting payment.
Businesses in those categories may now face both a federal rule and a state law. Aligning your pricing to one standard does not automatically satisfy the other, so the disclosure that survives review is the one built to meet both.
Where businesses get exposed
Pricing risk is often invisible until performance gets messy. The advertised number looks fine in isolation, but the problem appears when the customer reaches the checkout, the invoice, or the receipt and sees a different total.
The first job is to identify every mandatory charge added after the advertised price. The second is to confirm that every customer touchpoint tells the same pricing story.
- Price tags and shelf labels: the in-store number a customer relies on before reaching the register.
- Checkout and booking pages: the screens where fees are most likely to appear late in the flow.
- Receipts and invoices: automatic surcharges that never appeared in the advertised price.
- Advertisements: the promoted price that draws the customer in.
- POS systems and menus: the on-premise prices that may not match the website or the printed menu.
Restaurants and hospitality businesses may need separate treatment for service charges, gratuities, delivery fees, event fees, and credit-card surcharges. E-commerce and subscription businesses need disclosures before the consumer reaches final checkout. And a vendor platform can create exposure even when the business owner did not design the checkout flow.
These issues touch margin, collections, customer expectations, vendor leverage, and whether the business has a clean position if a fee dispute turns into a chargeback or a complaint. For businesses that run on agreements, the same care that goes into startup contracts should go into the language that governs how fees are presented and charged.
A scoped pricing-flow audit
A pricing-flow audit traces the entire path a price travels, from advertisement to checkout to invoice, and rewrites the language so fees are presented clearly, consistently, and defensibly. The goal is to turn confusion into a usable set of instructions before the 2027 deadline forces a rushed fix.
Depending on the facts, a defined project may include the following steps.
- Audit pricing language across menus, websites, booking pages, invoices, proposals, and customer contracts.
- Identify mandatory charges that should be folded into advertised pricing or disclosed differently.
- Draft compliant customer-facing fee disclosures and internal implementation notes.
- Review vendor, POS, and platform agreements to determine who controls pricing presentation.
- Prepare a January 1, 2027 compliance checklist for owners and managers.
The deliverable is concrete: a markup, a memo, a checklist, a risk map, or an implementation roadmap. A client is not just buying an opinion. The client is buying instructions a manager can act on. Where the document universe can be defined up front, this kind of work often fits a flat-fee scope, much like the structured engagements we describe in our guidance on when to hire a contract lawyer.
Disclosure problems also sit close to broader compliance systems. Businesses that already think in terms of regtech compliance can fold pricing transparency into the controls they monitor, rather than treating it as a one-time cleanup.
Who is affected by the new law
The Illinois junk fee ban reaches far beyond the headline targets. Any business that advertises a price and then adds a mandatory charge later should review its pricing flow.
- Restaurants and hospitality: service charges, automatic gratuities, delivery fees, and event minimums.
- Retail: mandatory surcharges, handling fees, and inconsistent shelf-to-register pricing.
- Subscription and membership businesses: activation, processing, or “convenience” fees described differently across pages.
- Event companies and venues: ticketing fees, facility fees, and booking surcharges.
- Online sellers and platforms: checkout fees added after the cart total.
Multi-location and online-plus-in-person operators carry extra risk because the same product can be priced through several systems at once. When the website, the app, the POS terminal, and the printed menu are maintained separately, they drift apart. Operations-heavy clients can coordinate that cleanup with their broader systems work, including the kind of process discipline that firms like Collateral Base bring to operations and compliance.
A staged path beats rebuilding twice
Pricing work is one of the better places to use a defined, phased scope. Rebuilding a checkout page, a POS configuration, and a menu twice is far more expensive than getting the legal language right the first time.
A sensible staged path may look like this.
- Phase 1: a pricing and fee-disclosure audit across every customer touchpoint.
- Phase 2: revised customer-facing disclosures and contract language.
- Phase 3: an implementation review for websites, POS systems, menus, and vendor platforms.
The business makes a decision at each stage. Start with the immediate issue, review the result, then decide whether the next phase is worth the spend. That is much easier to approve than an open-ended hourly engagement. The same logic that supports tight remedies in a contract, such as specific performance of a contract, supports tight, predictable scope here: define the deliverable, then deliver it.
Red flags that should make owners nervous
Some fee practices draw scrutiny on sight. If any of the following describe your business, review the pricing flow before the relationship becomes a payment fight, a chargeback, or a complaint.
- Mandatory service fees appear only at checkout.
- Menus show one price, but invoices include automatic surcharges.
- The business uses a third-party platform without reviewing how fees are displayed.
- Subscription or membership charges are described differently across pages.
- Managers give inconsistent explanations for the same fee.
Clean pricing is not only compliance; it is customer confidence. The fix is easier before enforcement letters, customer complaints, and class-action theories arrive. Businesses experimenting with newer payment and disclosure technology should also build transparency in from the start; our overview for a blockchain corporate attorney in Illinois covers how emerging tools and consumer-protection rules intersect.
If a fee dispute does escalate, the defense work belongs with counsel who handle that exposure. Our colleagues at Howard Law handle consumer-protection litigation defense when a pricing question becomes a claim.
Frequently Asked Questions
When does the Illinois junk fee ban take effect?
Governor Pritzker signed the Junk Fee Ban Act on June 25, 2026, and it takes effect January 1, 2027. That timeline gives businesses a defined window to audit pricing flows and update disclosures before the rules apply.
Does the law ban all fees, or just hidden ones?
The law targets surprise mandatory charges, not the existence of fees. The general principle is all-in pricing: if a charge is mandatory, it must be reflected in the advertised price or disclosed clearly and early, rather than revealed at the final checkout step. The specific application depends on your industry and facts.
How does the Illinois junk fee ban relate to the FTC rule?
The FTC Rule on Unfair or Deceptive Fees, effective May 12, 2025, applies to live-event tickets and short-term lodging at the federal level. The Illinois law adds a broader state requirement. Businesses in those categories may need to satisfy both, so disclosures should be drafted to meet the stricter standard that applies to them.
Next Steps
The price a customer sees should not become the lawsuit they file. With the Illinois junk fee ban set to take effect January 1, 2027, the practical move is to audit your pricing path now, while there is time to fix it deliberately rather than under pressure.
Howard East can scope a pricing-flow review tailored to your business, identify where mandatory fees create exposure, and draft disclosures that are clear, consistent, and defensible. To start a conversation about a defined-scope review, contact Howard East.
This article discusses Illinois law as of June 30, 2026 and is general information, not legal advice. No attorney-client relationship is created by reading it. Attorney Advertising.
