ILCS » Chapter 735 · Act 5
Illinois Compiled Statutes

735 ILCS 5/13-214.2 (2026)

(a) Actions based upon tort, contract or otherwise against any person, partnership or corporation registered pursuant to the Illinois Public Accounting Act, as amended, or any of its employees, partners, members, officers or shareholders, for an act or omission in the performance of professional services shall be commenced within 2 years from the time the person bringing an action knew or should reasonably have known of such act or omission

✓ current as of May 2026
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(735 ILCS 5/13-214.2) (from Ch. 110, par. 13-214.2)
    Sec. 13-214.2. (a) Actions based upon tort, contract or otherwise against any person, partnership or corporation registered pursuant to the Illinois Public Accounting Act, as amended, or any of its employees, partners, members, officers or shareholders, for an act or omission in the performance of professional services shall be commenced within 2 years from the time the person bringing an action knew or should reasonably have known of such act or omission.
    (b) In no event shall such action be brought more than 5 years after the date on which occurred the act or omission alleged in such action to have been the cause of the injury to the person bringing such action against a public accountant. Provided, however, that in the event that an income tax assessment is made or criminal prosecution is brought against a person, that person may bring an action against the public accountant who prepared the tax return within two years from the date of the assessment or conclusion of the prosecution.
    (c) If a person entitled to bring the action is, at the time the cause of action accrues, under the age of 18, or under a legal disability, the period of limitations shall not begin to run until the disability is removed.
    (d) This Section shall apply to all causes of action which accrue on or after its effective date.
(Source: P.A. 85-655; 86-1329.)

    
Notes of Decisions
Cited in 34 cases (4 in the last 5 years), 1995–2026 · leading case: Khan v. Seidman, LLP, 2012 IL App (4th) 120359 (Ill. App. Ct. 2012).
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Khan v. Seidman, LLP, 2012 IL App (4th) 120359 (Ill. App. Ct. 2012). · cites it 9× “2(a) (735 ILCS 5/13-214.2(a) (West 2008)), as well as the statute of repose in section 13-214.”
Khan v. Deutsche Bank AG, 2012 IL 112219 (Ill. 2012). · cites it 2× “2 of the Code (735 ILCS 5/13-214.2 (West 2008)). That statute provides in relevant part as follows: “(a) Actions based upon tort, contract or otherwise against any person, partnership or corporation registered pursuant to the Illinois Public Accounting Act, as amended, or any of…”
Federated Indus., Inc. v. Reisin, 927 N.E.2d 1253 (Ill. App. Ct. 2010). · cites it 3× “Defendants filed a motion to dismiss plaintiffs' complaint pursuant to section 2-619(a)(5) (735 ILCS 5/2-619(a)(5) (West 2008)), asserting that plaintiffs' complaint was filed beyond the applicable statute of limitations for accounting malpractice actions (735 ILCS 5/13-214.2(a)…”
Bova v. U.S. Bank, N.A., 446 F. Supp. 2d 926 (S.D. Ill. 2006). “2d 364 (1997), in which the court held that a similarly-worded statute of limitations governing actions against accountants, 735 ILCS 5/13-214.2, applied to a plaintiffs claim of fraud against a public accounting firm.”
Evanston Ins. Co. v. Riseborough, 2014 IL 114271 (Ill. 2014). · cites it 2× “3d 414, 424 (1997) (statute of limitations for actions against public accountants (735 ILCS 5/13-214.2(a) (West 1996)) was not limited to professional malpractice actions but applied to claims of fraud and tortious interference by former employee suing accounting firm);…”
Zurich Capital Markets Inc. v. Coglianese, 332 F. Supp. 2d 1087 (N.D. Ill. 2004). · cites it 2× “Statute of Limitations for State Law Claims Michael Coglianese and the Vorisek Defendants argue that all state claims against them are time-barred under the two year statute of limitations set forth in the Illinois Code of Civil Procedure, 735 ILCS 5/13-214.2(a). Section…”
Terrell v. Childers, 920 F. Supp. 854 (N.D. Ill. 1996). · cites it 3× “735 ILCS 5/13-214.2(a). According to the Kreger Defendants, the common law claims accrued in May 1991, when the Terrells hired a certified public accountant, Michael Sharpe, to audit the Terrells’ financial status and evaluate TSI’s management of their financial affairs; at the…”
Maniscalco v. Porte Brown, LLC, 2018 IL App (1st) 180716 (Ill. App. Ct. 2019). · cites it 3× “” 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
Evanston Ins. Co. v. Riseborough, 2014 IL 114271 (Ill. 2014). “20, 2006) (statute of repose for actions against public accountants (735 ILCS 5/13-214.2(b) (West 2004)) applied to the plaintiffs’ third-party action against the auditor of a failed bank, even though the auditor had not provided accounting services to the plaintiffs); Citgo…”
Cashman v. Coopers & Lybrand, 877 F. Supp. 425 (N.D. Ill. 1995). · cites it 2× “See 735 ILCS 5/13-214.2(a) (1993). 16 Even if Meagan Stotler, by her father, did not discover the claims raised in the present Complaint until the Elson/Guthrie action was filed on August 3, 1990, the statute of limitations for common law fraud ran on August 3, 1992, almost…”
Maniscalco v. Porte Brown, LLC, 2018 IL App (1st) 180716 (Ill. App. Ct. 2018). · cites it 5× “" 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
Lane v. Deutsche Bank, 2015 IL App (1st) 142968 (Ill. App. Ct. 2016). “735 ILCS 5/13-214.2(a) (West 2014). ¶ 18 As is apparent, the statutes differ not only in their length, but in their start dates.”
Show all 34 citing cases →
— 735 ILCS 5/13-214.2(a) — 27 cases
Khan v. Seidman, LLP, 2012 IL App (4th) 120359 (Ill. App. Ct. 2012). “2(a) (735 ILCS 5/13-214.2(a) (West 2008)), as well as the statute of repose in section 13-214.”
Federated Indus., Inc. v. Reisin, 927 N.E.2d 1253 (Ill. App. Ct. 2010). “Defendants filed a motion to dismiss plaintiffs' complaint pursuant to section 2-619(a)(5) (735 ILCS 5/2-619(a)(5) (West 2008)), asserting that plaintiffs' complaint was filed beyond the applicable statute of limitations for accounting malpractice actions (735 ILCS 5/13-214.2(a)…”
Zurich Capital Markets Inc. v. Coglianese, 332 F. Supp. 2d 1087 (N.D. Ill. 2004). “Statute of Limitations for State Law Claims Michael Coglianese and the Vorisek Defendants argue that all state claims against them are time-barred under the two year statute of limitations set forth in the Illinois Code of Civil Procedure, 735 ILCS 5/13-214.2(a). Section…”
Cashman v. Coopers & Lybrand, 877 F. Supp. 425 (N.D. Ill. 1995). “See 735 ILCS 5/13-214.2(a) (1993). 16 Even if Meagan Stotler, by her father, did not discover the claims raised in the present Complaint until the Elson/Guthrie action was filed on August 3, 1990, the statute of limitations for common law fraud ran on August 3, 1992, almost…”
Terrell v. Childers, 920 F. Supp. 854 (N.D. Ill. 1996). “735 ILCS 5/13-214.2(a). According to the Kreger Defendants, the common law claims accrued in May 1991, when the Terrells hired a certified public accountant, Michael Sharpe, to audit the Terrells’ financial status and evaluate TSI’s management of their financial affairs; at the…”
— 735 ILCS 5/13-214.2(b) — 10 cases
Khan v. Seidman, LLP, 2012 IL App (4th) 120359 (Ill. App. Ct. 2012). “2(a) (735 ILCS 5/13-214.2(a) (West 2008)), as well as the statute of repose in section 13-214.”
Evanston Ins. Co. v. Riseborough, 2014 IL 114271 (Ill. 2014). “20, 2006) (statute of repose for actions against public accountants (735 ILCS 5/13-214.2(b) (West 2004)) applied to the plaintiffs’ third-party action against the auditor of a failed bank, even though the auditor had not provided accounting services to the plaintiffs); Citgo…”
Evanston Ins. Co. v. Riseborough, 2014 IL 114271 (Ill. 2014). “3d 414, 424 (1997) (statute of limitations for actions against public accountants (735 ILCS 5/13-214.2(a) (West 1996)) was not limited to professional malpractice actions but applied to claims of fraud and tortious interference by former employee suing accounting firm);…”
Maniscalco v. Porte Brown, LLC, 2018 IL App (1st) 180716 (Ill. App. Ct. 2019). “” 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
Maniscalco v. Porte Brown, LLC, 2018 IL App (1st) 180716 (Ill. App. Ct. 2018). “" 735 ILCS 5/13-214.2(a) (West 2016). The parties agree that section 13-214.”
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