Key Takeaways
- Illinois HB 3564 requires all non-optional fees listed on the first page of the lease starting July 2026
- Tenants are not liable for any fees not disclosed in this manner
- Affected fees include application fees, pet fees, amenity fees, parking, trash, and any other mandatory charges
- The law applies statewide — every Illinois landlord, not just Chicago
- Combined with the Safer Homes Act, the first page of every IL lease now has two mandatory disclosures
What Is the Illinois Junk Fee Ban?
Effective July 2026, Illinois House Bill 3564 imposes a new statewide requirement on all residential landlords: every non-optional fee charged to tenants must be listed on the first page of the lease. If a fee is not disclosed in this manner, the tenant is not liable for it — period.
The law targets what consumer advocates and legislators have called “junk fees” — charges that inflate the true cost of renting beyond the advertised price. In practice, this means that the move-in cost a tenant actually pays can be hundreds or even thousands of dollars more than the listed rent due to application fees, pet deposits, amenity fees, administrative fees, and other charges that are not disclosed until after the tenant has committed to the property.
HB 3564 does not ban these fees. It bans hiding them. Landlords can still charge any fee they want, as long as it is clearly disclosed on the first page of the lease before the tenant signs. The law’s power comes from its remedy: if a fee is not listed on the first page, the tenant simply does not have to pay it.
Which Fees Must Be Disclosed
The law applies to all non-optional fees — any charge that the tenant must pay as a condition of renting the property. This includes but is not limited to:
| Fee Type | Must Disclose? | Notes |
|---|---|---|
| Application fee | Yes | Must be listed even though it is charged before the lease is signed |
| Security deposit | Yes | Amount and any non-refundable portion |
| Pet fee / pet deposit | Yes | Both one-time fees and monthly pet rent |
| Pet rent (monthly) | Yes | Separate from base rent |
| Parking fee | Yes | If parking is a mandatory charge (not optional) |
| Trash/recycling fee | Yes | If charged separately from rent |
| Amenity fee | Yes | Gym, pool, common area access fees |
| Administrative fee | Yes | Move-in fee, lease preparation fee, etc. |
| Technology / internet fee | Yes | If mandatory for all tenants |
| Utility billing fee (RUBS) | Yes | Ratio Utility Billing System administration fees |
| Late fee | Yes | Amount or formula and when it applies |
| Move-out cleaning fee | Yes | If a non-refundable charge (not deducted from deposit) |
| Optional services | No | Truly optional services (e.g., extra storage the tenant can decline) do not need first-page disclosure |
The First-Page Requirement
The law specifies that fees must be listed on the first page of the lease. This creates a practical challenge for landlords because the Safer Homes Act (also effective 2026) requires the state-issued Summary of Rights to be the first page of every lease. The two requirements must coexist.
In practice, this means the first page of an Illinois lease signed after July 2026 must contain:
- The Safer Homes Act Summary of Rights (or the fee disclosure on the same first page, depending on how the state publishes guidance)
- A complete list of all non-optional fees with amounts
The Illinois Attorney General’s office is expected to publish guidance on how to reconcile the two first-page requirements. Until then, landlords should plan to include both elements prominently on the first page of the lease, or use a two-part first page that satisfies both requirements.
What Happens If a Fee Is Not Disclosed
The remedy under HB 3564 is straightforward and powerful: the tenant is not liable for any fee that is not disclosed on the first page of the lease. This means:
- If you charge a $200 pet fee that is not listed on the first page, the tenant can refuse to pay it
- If you charge a monthly $50 amenity fee that is buried on page 12 of the lease, the tenant can stop paying it and you cannot evict for non-payment of that fee
- If you attempt to deduct an undisclosed move-out cleaning fee from the security deposit, the tenant can challenge the deduction
- If you charge a late fee that is not disclosed on the first page, the tenant can argue it is unenforceable
This is not a “reasonable notice” standard. The law is binary: the fee is either on the first page or it is not. If it is not, the tenant does not owe it. There is no cure period and no opportunity to amend the lease after the fact to retroactively disclose the fee.
Impact on Lease Templates
Most standard lease templates will need to be updated to comply with HB 3564. Common templates from national landlord websites, legal document services, and even some state-specific providers may not include a first-page fee disclosure section. Here is what needs to change:
Before HB 3564 (Typical Lease Structure)
- Page 1: Parties, property address, lease term, rent amount
- Pages 2–5: Lease terms and conditions
- Pages 6–8: Rules, maintenance responsibilities, signatures
- Attachments: Disclosures (scattered throughout)
After HB 3564 (Required Structure)
- Page 1: Safer Homes Act Summary of Rights + complete fee disclosure table
- Pages 2+: Parties, property address, lease term, rent amount, terms, conditions
- Attachments: Other required disclosures (RLTO summary, lead paint, etc.)
The fee disclosure should be a clear, readable table that lists every non-optional fee, its amount (or formula), and when it is charged. Do not bury fees in dense paragraph text — use a table format that tenants can easily scan and understand.
Fees Landlords Can Still Charge
HB 3564 does not ban any specific fee. It bans undisclosed fees. As long as a fee is listed on the first page of the lease, landlords can continue to charge:
- Application fees (within any applicable local limits)
- Security deposits (within any applicable local limits)
- Pet fees and pet rent
- Parking fees
- Amenity fees
- Administrative fees
- Late fees (within the RLTO formula for Chicago properties)
- Move-in/move-out fees
- Utility charges and RUBS fees
The key change is transparency, not prohibition. Tenants will see the full cost of renting before they sign, and landlords who have been relying on undisclosed fees to increase revenue will need to either disclose those fees (which may reduce demand) or eliminate them.
Interaction with Chicago RLTO
For Chicago landlords, HB 3564 interacts with existing RLTO provisions in several ways:
- Late fees — the RLTO already limits late fees to the $10 + 5% formula. HB 3564 adds the requirement that the late fee amount or formula must be disclosed on the first page of the lease. A late fee that complies with the RLTO formula but is not disclosed on the first page may be unenforceable under HB 3564.
- Security deposit — the deposit amount must now be on the first page in addition to being documented in the 14-day receipt required by the RLTO.
- Application fees — while application fees are charged before the lease is signed, they must still be disclosed on the first page of the lease. This allows tenants to verify after the fact that the application fee they paid matches the disclosed amount.
Practical Compliance Checklist
- Inventory all fees you currently charge tenants — base rent, security deposit, application fee, pet fee, pet rent, parking, trash, amenity, admin, late fee, move-in/out, utility, technology, and any other charges
- Create a fee disclosure table listing each fee, its amount (or formula), frequency (one-time, monthly, annual), and when it is charged
- Add the table to the first page of your lease template, alongside the Safer Homes Act Summary of Rights
- Review every lease before signing to ensure the fee disclosure is current and complete
- Update the disclosure whenever fees change — if you add a new fee mid-tenancy, it must be disclosed before it can be charged
- Train your team (if you have one) on the first-page requirement and the consequence of missing a fee
Frequently Asked Questions
Does this apply to leases signed before July 2026?
No. HB 3564 applies to leases signed on or after the effective date in July 2026. Existing leases are not retroactively affected. However, when those leases renew and a new lease document is signed, the fee disclosure must be included on the first page of the new lease.
What if I add a new fee after the lease is signed?
If you want to charge a new fee that was not disclosed on the first page of the original lease, you must provide the tenant with a written amendment disclosing the fee before it can be charged. The tenant is not liable for any fee that was not disclosed at the time of signing or properly amended thereafter. Note that adding fees mid-lease may also be subject to the Fair Notice Ordinance’s tiered notice requirements in Chicago.
Are optional services affected?
Truly optional services — those that the tenant can decline without affecting their tenancy — are generally not subject to the first-page disclosure requirement. Examples include optional storage unit rental, optional pet DNA testing services, or optional renter’s insurance purchased through the landlord. However, if a “optional” fee is practically mandatory (e.g., the only way to access the building’s gym), it may be considered non-optional and subject to disclosure.
Can I just include “see lease for details” on the first page?
No. The law requires the fees to be listed on the first page, not referenced. A cross-reference to another page does not satisfy the requirement. The actual fee amounts must appear on the first page of the lease.
What about rent increases — is that a “fee”?
Rent itself is not a “fee” under HB 3564. The base monthly rent does not need to be listed in the fee disclosure (though it should obviously appear in the lease). The law targets charges in addition to base rent. However, if you charge rent components separately (e.g., base rent + mandatory utility surcharge + mandatory amenity fee), the surcharges and fees must be disclosed.