ILCS » Chapter 225 · Act 450
Illinois Compiled Statutes

225 ILCS 450/30.1 (2026)

Liability

✓ current as of May 2026
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(225 ILCS 450/30.1) (from Ch. 111, par. 5535.1)
    (Section scheduled to be repealed on January 1, 2029)
    Sec. 30.1. Liability. No person, partnership, corporation, or other entity licensed or authorized to practice under this Act or any of its employees, partners, members, officers or shareholders shall be liable to persons not in privity of contract with such person, partnership, corporation, or other entity for civil damages resulting from acts, omissions, decisions or other conduct in connection with professional services performed by such person, partnership, corporation, or other entity, except for:
        (1) such acts, omissions, decisions or conduct that
    
constitute fraud or intentional misrepresentations, or
        (2) such other acts, omissions, decisions or conduct,
    
if such person, partnership or corporation was aware that a primary intent of the client was for the professional services to benefit or influence the particular person bringing the action; provided, however, for the purposes of this subparagraph (2), if such person, partnership, corporation, or other entity (i) identifies in writing to the client those persons who are intended to rely on the services, and (ii) sends a copy of such writing or similar statement to those persons identified in the writing or statement, then such person, partnership, corporation, or other entity or any of its employees, partners, members, officers or shareholders may be held liable only to such persons intended to so rely, in addition to those persons in privity of contract with such person, partnership, corporation, or other entity.
(Source: P.A. 98-254, eff. 8-9-13.)

    
Notes of Decisions
Cited in 28 cases, 1994–2019 · leading case: Arlene Atlas v. Mayer Hoffman McCann, P.C., 2019 IL App (1st) 180939 (Ill. App. Ct. 2019).
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Arlene Atlas v. Mayer Hoffman McCann, P.C., 2019 IL App (1st) 180939 (Ill. App. Ct. 2019). · cites it 5× “¶4 On appeal, plaintiffs contend that the circuit court committed reversible error when it dismissed their accounting malpractice claims against the Mayer defendants because they: (1) are liable to plaintiffs pursuant to the Illinois Public Accounting Act (Act) (225 ILCS…”
Builders Bank v. Barry Finkel & Assocs., 790 N.E.2d 30 (Ill. App. Ct. 2003). · cites it 9× “The trial court granted defendant’s motion to dismiss plaintiffs amended complaint. Plaintiff appeals, claiming that the trial court erred by misinterpreting section 30.”
Freeman, Freeman & Salzman, P.C. v. Lipper, 812 N.E.2d 562 (Ill. App. Ct. 2004). · cites it 12× “1 of the Illinois Public Accounting Act (225 ILCS 450/30.1 (West 2002)). On August 26, 2003, the trial court dismissed the claims against PWC with prejudice on the basis that PWC did not owe a duty to plaintiffs.”
Fed. Deposit Ins. Corp. v. Ernst & Young LLP, 374 F.3d 579 (7th Cir. 2004). · cites it 4× “225 ILCS 450/30.1(1). It allows third parties to recover for ordinary negligence (which the FDIC also alleges) if the accountant knew that “a primary intent of the client was for the professional services to benefit .”
Kopka v. Kamensky & Rubenstein, 821 N.E.2d 719 (Ill. App. Ct. 2004). · cites it 3× “1 (West 2002)) specifically provides that an accountant may be held liable to persons not in privity when "such person, partnership or corporation was aware that a primary intent of the client was for the professional services to benefit or influence the particular person…”
Tricontinental Indus., Ltd. & Tricontinental Distrib., Ltd. v. Pricewaterhousecoopers, LLP, 475 F.3d 824 (7th Cir. 2007). “Shortly after Brumley II, the Illinois legislature enacted the Illinois Public Accounting Act, 225 ILCS 450/30.1, which provides: No person, partnership, corporation, or other entity licensed or authorized to practice under this Act .”
Bank of Am., N.A. v. Knight, 725 F.3d 815 (7th Cir. 2013). “They invoked the protection of 225 ILCS 450/30.1, which provides that an accountant is liable only to its clients unless the accountant itself committed fraud (which no one alleges here) or “was aware that a primary intent of the client was for the professional services to…”
RS Investments Ltd. v. RSM US, LLP, 2019 IL App (1st) 172410 (Ill. App. Ct. 2019). · cites it 3× “for the professional services to benefit or influence the particular person bringing the action; provided, however, for the purposes of this subparagraph (2), if such person, partnership, corporation, or other entity (i) identifies in writing to the client those persons who are…”
Chestnut Corp. v. Pestine, Brinati, Gamer, Ltd., 667 N.E.2d 543 (Ill. App. Ct. 1996). · cites it 2× “JUSTICE CAHILL delivered the opinion of the court: We address the liability of an accountant, under the Illinois Public Accounting Act (Act) (225 ILCS 450/30.1 (West 1992)), for negligent misrepresentation to a third party with whom the accountant is not in privity.”
Kopka v. Kamensky & Rubenstein, 354 Ill. App. 3d 930 (Ill. App. Ct. 2004). · cites it 3× “1 of the Illinois Public Accounting Act (Act) (225 ILCS 450/30.1 (West 2002)) specifically provides that an accountant may be held liable to persons not in privity when “such person, partnership or corporation was aware that a primary intent of the client was for the…”
Lutkauskas v. Ricker, 2015 IL 117090 (Ill. 2015). “Knutte also sought dismissal of count III under section 2-619 on the ground that plaintiffs lacked standing to sue under the Illinois Public Accounting Act (225 ILCS 450/30.1 (West 2010)). ¶ 14 On July 17, 2011, the circuit court granted the motions to dismiss filed by the…”
Maxwell v. KPMG LLP, 520 F.3d 713 (7th Cir. 2008). “The same conclusions can be reached by a different route, by asking what duty, enforceable by tort law, was assumed by KPMG as Whittman-Hart’s auditor.”
Show all 28 citing cases →
— 225 ILCS 450/30.1(1) — 3 cases
Fed. Deposit Ins. Corp. v. Ernst & Young LLP, 374 F.3d 579 (7th Cir. 2004). “225 ILCS 450/30.1(1). It allows third parties to recover for ordinary negligence (which the FDIC also alleges) if the accountant knew that “a primary intent of the client was for the professional services to benefit .”
Dougherty v. Zimbler, 922 F. Supp. 110 (N.D. Ill. 1996).
Detterbeck v. Detterbeck, 2019 IL App (1st) 181113-U (Ill. App. Ct. 2019).
— 225 ILCS 450/30.1(2) — 10 cases
Fed. Deposit Ins. Corp. v. Ernst & Young LLP, 374 F.3d 579 (7th Cir. 2004). “225 ILCS 450/30.1(1). It allows third parties to recover for ordinary negligence (which the FDIC also alleges) if the accountant knew that “a primary intent of the client was for the professional services to benefit .”
Builders Bank v. Barry Finkel & Assocs., 790 N.E.2d 30 (Ill. App. Ct. 2003). “The trial court granted defendant’s motion to dismiss plaintiffs amended complaint. Plaintiff appeals, claiming that the trial court erred by misinterpreting section 30.”
RS Investments Ltd. v. RSM US, LLP, 2019 IL App (1st) 172410 (Ill. App. Ct. 2019). “for the professional services to benefit or influence the particular person bringing the action; provided, however, for the purposes of this subparagraph (2), if such person, partnership, corporation, or other entity (i) identifies in writing to the client those persons who are…”
RS Investments Ltd. v. RSM US, LLP, 2019 IL App (1st) 172410 (Ill. App. Ct. 2019).
Peterson ex rel. estates of Lancelot Investors Fund, Ltd. v. McGladrey LLP, 792 F.3d 785 (7th Cir. 2015).
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