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Illinois Compiled Statutes

810 ILCS 5/2-201 (2026)

Formal requirements; statute of frauds

✓ current as of May 2026
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(810 ILCS 5/2-201) (from Ch. 26, par. 2-201)
    Sec. 2-201. Formal requirements; statute of frauds.
    (1) Except as otherwise provided in this Section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is a record sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by the party's authorized agent or broker. A record is not insufficient because it omits or incorrectly states a term agreed upon but the contract is not enforceable under this subsection beyond the quantity of goods shown in the record.
    (2) Between merchants if within a reasonable time a record in confirmation of the contract and sufficient against the sender is received and the party receiving it has reason to know its contents, it satisfies the requirements of subsection (1) against the party unless notice in a record of objection to its contents is given within 10 days after it is received.
    (3) A contract which does not satisfy the requirements of subsection (1) but which is valid in other respects is enforceable
        (a) if the goods are to be specially manufactured for
    
the buyer and are not suitable for sale to others in the ordinary course of the seller's business and the seller, before notice of repudiation is received and under circumstances which reasonably indicate that the goods are for the buyer, has made either a substantial beginning of their manufacture or commitments for their procurement; or
        (b) if the party against whom enforcement is sought
    
admits in his pleading, testimony or otherwise in court that a contract for sale was made, but the contract is not enforceable under this provision beyond the quantity of goods admitted; or
        (c) with respect to goods for which payment has been
    
made and accepted or which have been received and accepted (Section 2-606).
(Source: P.A. 103-1036, eff. 1-1-25.)

    
Notes of Decisions
Cited in 36 cases (12 in the last 5 years), 1995–2025 · leading case: Cent. Illinois Light Co. v. Consolidation Coal Co., 235 F. Supp. 2d 916 (C.D. Ill. 2002).
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Cent. Illinois Light Co. v. Consolidation Coal Co., 235 F. Supp. 2d 916 (C.D. Ill. 2002). · cites it 8× “” 810 ILCS 5/2-201, cmt. 1. Comment 1 also clarifies the writing that is required: The required writing need not contain all the material terms of the contract and such material terms as are stated need not be precisely stated; All that is required is that the writing afford a…”
Caterpillar, Inc. v. Usinor Industeel, 393 F. Supp. 2d 659 (N.D. Ill. 2005). · cites it 2× “810 ILCS 5/2-201(1). In Illinois, “the statute of frauds is applicable to a promise claimed to be enforceable by virtue of the doctrine of promissory estoppel.”
Miller v. Dep't of Agric., 2024 IL 128508 (Ill. 2024). · cites it 2× “2d 585, 589 (1975)), the ALJ determined section 2- 201 requires some writing sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by his authorized agent or broker (see 810 ILCS 5/2-201…”
Tibor Mach. Prods., Inc. v. Freudenberg-Nok Gen. P'ship, 967 F. Supp. 1006 (N.D. Ill. 1997). · cites it 4× “810 ILCS 5/2-201(1) (1993); 13 see also A-Abart Elec.”
Vanguard Energy Servs., L.L.C. v. Shihadeh, 2017 IL App (2d) 160909 (Ill. App. Ct. 2017). · cites it 6× “Defendant filed a motion to dismiss 2017 IL App (2d) 160909 pursuant to section 2-619(a)(7) of the Code of Civil Procedure (Code) (735 ILCS 5/2-619(a)(7) (West 2014)), arguing that the breach-of-contract claims were barred by the statute of frauds contained in section 2-201 of…”
Miwel, Inc. v. Kanzler, 2019 IL App (2d) 180931 (Ill. App. Ct. 2019). “Earth further contended that, if there was an assignment, it was unenforceable under the statute of frauds in the Uniform Commercial Code (UCC) (810 ILCS 5/2-201 (West 2016)). ¶7 The trial court entered summary judgment for defendants on the counts of the amended complaint…”
Indus. Specialty Chemicals, Inc. v. Cummins Engine Co., 902 F. Supp. 805 (N.D. Ill. 1995). “Nor has our independent review of the exhibits attached to the complaint uncovered any document, signed by the defendants, which sufficiently indicates that a contract for the sale of goods was made. 7 However, at this juncture we cannot say that plaintiff will be unable to seek…”
United Potato Co., Inc. v. Burghard & Sons, Inc., 18 F. Supp. 2d 894 (N.D. Ill. 1998). · cites it 2× “Statute of Frauds BSI argues both the Illinois Frauds Act (“Frauds Act”), 740 ILCS 80/1, and the Uniform Commercial Code’s (“UCC”) Statute of Frauds provision, as adopted in Illinois, 810 ILCS 5/2-201, are applicable to this case and bar this action.”
Armagan v. Pesha, 2014 IL App (1st) 121840 (Ill. App. Ct. 2014). “¶ 40 Defendants next argue that because there is no writing to evidence the agreement for defendants to store the coins, plaintiff’s claims are barred by the statute of frauds found in section 2-201 of the Uniform Commercial Code (810 ILCS 5/2-201 (West 2010)). Article 2 of the…”
Vanguard Energy Servs., L.L.C. v. Shihadeh, 2017 IL App (2d) 160909 (Ill. App. Ct. 2017). · cites it 5× “” 810 ILCS 5/2-201(1) (West 2014). ¶ 14 Plaintiff does not dispute that its product, natural gas, is considered “goods” and that, on its face, section 2-201(1) is applicable because counts I and II relate to oral agreements.”
Indus. Specialty Chemicals v. Cummins Engine Co., 918 F. Supp. 1173 (N.D. Ill. 1996). · cites it 3× “810 ILCS 5/2-201(1). 7 . As we have disposed of Count IV in its entirety, we need not address the defendants' arguments for partial summary judgment.”
Carl A. Haas Auto. Imports, Inc. v. Lola Cars Ltd., 933 F. Supp. 1381 (N.D. Ill. 1996). “2 contains its own statute of frauds (810 ILCS 5/2-201(1)): Except as otherwise provided in this Section 8 a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is some writing sufficient to indicate that a…”
Show all 36 citing cases →
— 810 ILCS 5/2-201(1) — 21 cases
Caterpillar, Inc. v. Usinor Industeel, 393 F. Supp. 2d 659 (N.D. Ill. 2005). “810 ILCS 5/2-201(1). In Illinois, “the statute of frauds is applicable to a promise claimed to be enforceable by virtue of the doctrine of promissory estoppel.”
Tibor Mach. Prods., Inc. v. Freudenberg-Nok Gen. P'ship, 967 F. Supp. 1006 (N.D. Ill. 1997). “810 ILCS 5/2-201(1) (1993); 13 see also A-Abart Elec.”
Carl A. Haas Auto. Imports, Inc. v. Lola Cars Ltd., 933 F. Supp. 1381 (N.D. Ill. 1996). “2 contains its own statute of frauds (810 ILCS 5/2-201(1)): Except as otherwise provided in this Section 8 a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is some writing sufficient to indicate that a…”
Cent. Illinois Light Co. v. Consolidation Coal Co., 235 F. Supp. 2d 916 (C.D. Ill. 2002). “” 810 ILCS 5/2-201, cmt. 1. Comment 1 also clarifies the writing that is required: The required writing need not contain all the material terms of the contract and such material terms as are stated need not be precisely stated; All that is required is that the writing afford a…”
Bensdorf & Johnson, Inc. v. N. Telecom Ltd., 58 F. Supp. 2d 874 (N.D. Ill. 1999).
— 810 ILCS 5/2-201(2) — 11 cases
Cent. Illinois Light Co. v. Consolidation Coal Co., 235 F. Supp. 2d 916 (C.D. Ill. 2002). “” 810 ILCS 5/2-201, cmt. 1. Comment 1 also clarifies the writing that is required: The required writing need not contain all the material terms of the contract and such material terms as are stated need not be precisely stated; All that is required is that the writing afford a…”
Miller v. Dep't of Agric., 2024 IL 128508 (Ill. 2024). “2d 585, 589 (1975)), the ALJ determined section 2- 201 requires some writing sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by his authorized agent or broker (see 810 ILCS 5/2-201…”
Vanguard Energy Servs., L.L.C. v. Shihadeh, 2017 IL App (2d) 160909 (Ill. App. Ct. 2017). “Defendant filed a motion to dismiss 2017 IL App (2d) 160909 pursuant to section 2-619(a)(7) of the Code of Civil Procedure (Code) (735 ILCS 5/2-619(a)(7) (West 2014)), arguing that the breach-of-contract claims were barred by the statute of frauds contained in section 2-201 of…”
Miller v. Dep't of Agric., 2022 IL App (4th) 210204 (Ill. App. Ct. 2022).
Vanguard Energy Servs., L.L.C. v. Shihadeh, 2017 IL App (2d) 160909 (Ill. App. Ct. 2017). “” 810 ILCS 5/2-201(1) (West 2014). ¶ 14 Plaintiff does not dispute that its product, natural gas, is considered “goods” and that, on its face, section 2-201(1) is applicable because counts I and II relate to oral agreements.”
— 810 ILCS 5/2-201(3) — 3 cases
Tibor Mach. Prods., Inc. v. Freudenberg-Nok Gen. P'ship, 967 F. Supp. 1006 (N.D. Ill. 1997). “810 ILCS 5/2-201(1) (1993); 13 see also A-Abart Elec.”
Kessebohmer Retail Merchandising Inc. v. Pete's Fresh Mkt. 4700 Corp. (N.D. Ill. 2024).
Kessebohmer Retail Merchandising Inc. v. Pete's Fresh Mkt. 4700 Corp. (N.D. Ill. 2025).
— 810 ILCS 5/2-201(3)(a) — 4 cases
Vanguard Energy Servs., L.L.C. v. Shihadeh, 2017 IL App (2d) 160909 (Ill. App. Ct. 2017). “Defendant filed a motion to dismiss 2017 IL App (2d) 160909 pursuant to section 2-619(a)(7) of the Code of Civil Procedure (Code) (735 ILCS 5/2-619(a)(7) (West 2014)), arguing that the breach-of-contract claims were barred by the statute of frauds contained in section 2-201 of…”
Vanguard Energy Servs., L.L.C. v. Shihadeh, 2017 IL App (2d) 160909 (Ill. App. Ct. 2017). “” 810 ILCS 5/2-201(1) (West 2014). ¶ 14 Plaintiff does not dispute that its product, natural gas, is considered “goods” and that, on its face, section 2-201(1) is applicable because counts I and II relate to oral agreements.”
Kessebohmer Retail Merchandising Inc. v. Pete's Fresh Mkt. 4700 Corp. (N.D. Ill. 2024).
Kessebohmer Retail Merchandising Inc. v. Pete's Fresh Mkt. 4700 Corp. (N.D. Ill. 2025).
— 810 ILCS 5/2-201(3)(b) — 3 cases
Indus. Specialty Chemicals, Inc. v. Cummins Engine Co., 902 F. Supp. 805 (N.D. Ill. 1995). “Nor has our independent review of the exhibits attached to the complaint uncovered any document, signed by the defendants, which sufficiently indicates that a contract for the sale of goods was made. 7 However, at this juncture we cannot say that plaintiff will be unable to seek…”
Indus. Specialty Chemicals v. Cummins Engine Co., 918 F. Supp. 1173 (N.D. Ill. 1996). “810 ILCS 5/2-201(1). 7 . As we have disposed of Count IV in its entirety, we need not address the defendants' arguments for partial summary judgment.”
Jannusch v. Naffziger (Ill. App. Ct. 2008).
— 810 ILCS 5/2-201(3)(c) — 2 cases
Masad Food Indus. v. Int'l Golden Foods, Inc. (N.D. Ill. 2025).
Jannusch v. Naffziger (Ill. App. Ct. 2008).
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