In February 2009, we issued a Management Alert regarding the Illinois Vendor Registration Act (P.A. 095-0971), which requires, among other things, that business entities whose contracts and/or bids with Illinois agencies exceed $50,000 must register with the Illinois Board of Elections, and those bidding on contracts must execute a registration certificate. Concurrent with the enactment of this new law, Executive Order 3 (2008) was issued and forbade entities from contributing or soliciting contributions on behalf of a state officer or candidate for state office, beginning on the date a request for proposal (RFP) is issued and ending on the day after the contract is awarded, at any time after an entity is awarded a contract but before its start, for the duration of the contract and for two years thereafter.

Since we issued that Management Alert, Executive Order 3 (2008) was rescinded by Governor Quinn. While the Executive Order has been rescinded, vendors to state agencies should be aware that the provisions of the Illinois Vendor Registration Act regarding campaign contributions remain in effect.

In addition to the rescission of Executive Order 3, guidance has been published  

  • regarding which entities are “state agencies” for purposes of the Illinois Vendor Registration Act. This list can be found by going to, and clicking on “What all state vendors need to know about new ethics requirements.”  
  • clarifying that if a contract is for an indeterminate amount – as is generally the case for service contracts – the vendor will be required to register once the value of “orders” placed (i.e., services rendered or invoices sent) exceeds $50,000.