3.1 Illinois Cosmetology Act & IDFPR Licensure Rules

3.1 Illinois Cosmetology Act & IDFPR Licensure Rules

In the State of Illinois, the professional practice of cosmetology is strictly regulated to protect public health, safety, and consumer welfare. Practitioners must master both the governing statutory legislation and the administrative regulations that define licensing qualifications, scope of practice, workplace standards, and disciplinary procedures.

Statutory Framework: 225 ILCS 410 and Title 68 Part 1175

Cosmetology regulation in Illinois is anchored by primary statutory legislation: the Illinois Barber, Cosmetology, Esthetics, Hair-Braiding, and Nail Technology Act of 1985 (codified under 225 ILCS 410). The detailed operational rules that execute this Act are set forth in the Title 68 Illinois Administrative Code Part 1175.

Together, the Act and Administrative Code define cosmetology as any one or combination of the following practices performed on the human head, face, neck, hair, skin, or nails for cosmetic beautification: cutting, trimming, styling, arranging, dressing, curling, waving, chemical restructuring, relaxing, bleaching, tinting, coloring, cleansing, conditioning, facials, skin care, depilatory waxing, manicuring, and pedicuring. Under 225 ILCS 410/4-20, practicing or attempting to practice cosmetology without a license is a Class B misdemeanor for the first offense, a Class A misdemeanor for the second offense, and a Class 4 felony for all subsequent offenses, with a fine of not less than $1,000 and not more than $5,000. Section 4-20 applies the same escalating penalties to obtaining a license by fraudulent misrepresentation and — a rule worth memorizing — to using any technique, product, or practice intended to affect the living layers of the skin. Separately, Section 1-7.5 authorizes IDFPR to assess a civil penalty of up to $5,000 per offense for unlicensed practice.

IDFPR Regulatory Authority and the Cosmetology Board

The state agency responsible for licensing, regulating, and disciplining cosmetologists in Illinois is the Illinois Department of Financial and Professional Regulation (IDFPR), operating through its Division of Professional Regulation. Within IDFPR, the Barber, Cosmetology, Esthetics, Hair Braiding, and Nail Technology Board functions as a statutory advisory body.

The Board is composed of governor-appointed industry professionals, educators, and public consumer members. Its statutory duties include:

• Formulating and recommending administrative rules governing sanitation, safety, and school curricula.
• Conducting formal disciplinary hearings regarding licensee misconduct, fraud, or sanitary violations.
• Advising the IDFPR Director on professional competency standards and testing parameters.
• Reviewing reciprocity and endorsement applications from out-of-state practitioners.

Licensure Prerequisites and Training Pathways

To qualify for an initial cosmetologist license in Illinois under 225 ILCS 410/3-2, an applicant must satisfy clear statutory requirements before applying for examination:

1. Age Requirement: The candidate must be at least 16 years of age.
2. General Education: Under 68 Ill. Adm. Code 1175.400(a)(2), the applicant must be a high school graduate or its equivalent or be beyond the age of compulsory school attendance. Note the "or" — a diploma is not strictly mandatory if the applicant is past compulsory school age.
3. Professional Training Hours: Under 68 Ill. Adm. Code 1175.400(a)(3), the candidate must graduate either from a cosmetology school approved by the Division (225 ILCS 410/3-2) or, under the barber-school route in 225 ILCS 410/3-3, from a licensed barbering school with 1,500 barbering hours plus at least 500 additional hours of cosmetology study over no less than 3 months. A cosmetology school may also credit up to 1,000 hours of licensed barber-school training toward its own 1,500-hour program. Through December 31, 2026, 225 ILCS 410/3-6 lets a candidate apply to CTS to sit for the exam after 1,200 hours (pre-graduation filing), but IDFPR will not issue the license until proof of all 1,500 hours and graduation is submitted. Public Act 104-478 deletes that 1,200-hour sentence effective January 1, 2027. Section 3-6 still lets IDFPR provide by rule for testing before training is complete, so check the current CTS instructions before filing early after that date.
4. Abnormal Skin Growth Education: Under 225 ILCS 410/1-7.10, added by Public Act 103-851, every applicant who files for original licensure on or after January 1, 2026 must provide proof of completing a Department-approved course in abnormal skin growth education, including training on identifying melanoma. Licensees who were already licensed before that date must complete it with their first renewal or restoration filed on or after January 1, 2026. IDFPR is still promulgating rules for this requirement. Until they take effect, its Statement Regarding P.A. 103-0851 (August 21, 2025) approves the free online "Skinny on Skin" program by Impact Melanoma, Inc., and the certificate of completion is filed with the application. Part 1175 does not yet contain a rule section on abnormal skin growth education. A licensee who completes the course and then refers a client to a physician — or does not — is protected from civil and criminal liability for acting or failing to act in good faith on that information.

The school pathway demands 1,500 hours of instruction spanning infection control, chemical texture services, hair coloring, cutting, hair design, aesthetics, and nail technology, and it is the only route to the Illinois cosmetology examination today — 1175.400(a)(3) recognizes graduation from an approved cosmetology school or barber school and nothing else. Public Act 104-478 adds an apprenticeship route at 225 ILCS 410/1-15 effective January 1, 2027: 3,000 hours of practical training in a sponsoring licensed salon or shop, including 180 hours of related supplemental instruction, supervised by a licensee with at least 3 years of experience or a teacher license, under a written apprenticeship agreement paying at least the State minimum wage. Until that date an apprenticeship does not qualify a candidate to sit for the examination.

Examination Administration: CTS, PSI, and the 75% Cut Score

Licensure examinations in Illinois are administered through a partnership between Continental Testing Services (CTS) and PSI testing centers. Candidates who complete their educational hours submit an examination application through CTS, which verifies credentials and grants scheduling authorization.

Key examination parameters, taken from the CTS/PSI Illinois Cosmetology Examinations candidate guide (effective 10/1/2026) and the CTS 011 Licensed Cosmetologist page, include:

• Format: Computer-administered examination of 110 questions: 100 scored items plus 10 unscored pretest items. Pretest results do not count toward your score, so answer every question as if it counts.
• Testing Duration: The time limit for the examination is 120 minutes (2 hours) — a little over one minute per question. The pre-exam computer tutorial does not count against that time, but the clock keeps running during personal breaks.
• Passing Grade: 75 or higher. This is set by rule at 68 Ill. Adm. Code 1175.410(b), not by the vendor.
• No Practical Hands-On Exam: Illinois requires only this written examination for cosmetologist licensure. Clinical procedure, draping, and sanitation competence are tested through written scenario items rather than a live model or mannequin performance.
• Languages: Computerized forms in English, Spanish, Simplified Chinese, Korean, and Vietnamese. The candidate selects a language on the CTS application.
• Examination Fee: CTS lists $200 for the computerized cosmetology examination in each of the five languages. CTS does not refund testing fees.
• Scheduling: After CTS approves the application, PSI emails scheduling instructions. The candidate must complete the test within 60 days of that approval or forfeit the fee. Regular appointments must be booked at least two business days ahead; approved accommodations must be booked at least two weeks ahead through the PSI call center.
• Results: An unofficial score report prints at the test center; the official CTS score report follows one to two weeks after the test date. Candidates who fail receive a diagnostic report showing the content areas that need work.

The Official CTS Content Outline (Effective October 1, 2026)

The examination is based on recommendations from licensed cosmetology teachers throughout Illinois. CTS lists three supporting references: Milady Standard Cosmetology, 14th edition (2023); Milady Standard Foundations, 1st edition (2020); and Pivot Point Fundamentals: Cosmetology, 2nd edition (2024). The 100 scored items are divided across ten content areas. Memorize these weights — they tell you exactly where to spend study time:

Three structural facts follow from that table. First, safety and client analysis are nearly half the test: Safety and Infection Control (30%) and Client Consultation and Hair, Skin, and Nail Analysis (19%) account for 49 of the 100 scored items, and every service area adds safety subareas of its own (thermal-tool precautions, safe use of color and lighteners, chemical texturing precautions, hair removal and nail infection control). Second, cutting and styling are small: Haircutting (3%) and Hairstyling (2%) are only five scored items combined, while the two chemical areas — Chemical Texture Services (12%) and Haircoloring (10%) — are 22. Third, this is an Illinois-specific CTS examination, not the NIC national cosmetology theory exam that many other states use. Study material written to the NIC blueprint (Scientific Concepts, Hair Care and Services, Skin Care and Services, Nail Care and Services) describes a different test, and material quoting the earlier seven-area Illinois outline (Salon Safety and Sanitation 32%, three hair areas at 13% each) predates the October 1, 2026 revision.

The outline has no separate Illinois law area. The Illinois rules in this chapter still govern licensure and daily practice, and the Part 1175 sanitation rules overlap heavily with Safety and Infection Control.

Retesting Limitations and the 100-Hour Remedial Rule

Under 68 Ill. Adm. Code 1175.410, candidates must satisfy specific timelines and remedial conditions when attempting to pass the examination:

• Application Validity: A CTS application remains valid for three years. An applicant who does not pass within that window must reapply as a new applicant and resubmit all supporting documentation.
• Retest Waiting Period: A failed candidate must wait for the official CTS results letter before reapplying, and all retake applicants must wait 30 days before reapplying to CTS. By rule, a written retake request must be made at least 45 days in advance of the examination date and must include the examination fee.
• The Three-Failure Rule: An applicant who fails a third examination must submit an official transcript from a licensed cosmetology school showing successful completion of either a 100-hour refresher course or the 250-hour cosmetology refresher course (see Section 1175.531) before taking the examination a fourth time.
• Waiver of Remediation: The Division may waive the remedial training in whole or in part on proof that the applicant has demonstrated competence to sit again. It weighs the margin by which the applicant failed, the number of failures, and any extenuating circumstances. The refresher requirement is therefore a rule with a documented exception, not an absolute bar.
• The Counter Resets: For retake purposes, the fourth attempt counts as the first. There is no lifetime cap on attempts.
• The Post-Pass Clock (rule and statute disagree): Passing the exam does not itself grant a license. 68 Ill. Adm. Code 1175.410(d), unamended since 2018, says an applicant who has not applied for licensure within 12 months of passing must retake the examination. Public Act 104-153, effective January 1, 2026, rewrote 225 ILCS 410/4-5(e) to allow 3 years from notification of passing, and the statute controls over the stale rule. Apply as soon as the CTS results letter arrives rather than testing the gap.

License Display, Salon Shop Licensure, and Mobile Units

Once a license is issued by IDFPR, practitioners and salon owners must maintain strict compliance regarding workplace display and business licensing.

Individual License Display

The display rule is statutory, at 225 ILCS 410/1-10, and it is about the client's line of sight, not the stylist's chair. Every license holder must display the license in a prominent place in the salon or shop where clients enter or wait to receive services, and in that same prominent location must also display the sign supplied by the Department carrying information about the Act and rules, sanitary requirements, and the contact details for IDFPR's complaint intake unit. There is no rule requiring a photograph to be attached to the displayed license — that is a persistent salon myth.

When a licensee performs services outside of or away from the salon or shop, Section 1-10 requires the licensee to furnish proof of a valid Illinois license to any person who asks.

Salon Shop Registration

A salon or barber shop operates under a certificate of registration issued by IDFPR under Article IIID of the Act and 68 Ill. Adm. Code 1175.1300, separate from any individual practitioner license. The certificate must be displayed in a prominent place where clients enter or wait, alongside the same Department sign. Registration is required for a storefront or free-standing salon, a mobile salon or shop, a booth-rental facility (either the owner registers the whole facility or each renting licensee registers individually), a kiosk or similar structure inside another business, and a business that contracts to provide services on the premises of a facility such as a healthcare or residential facility. A change of location requires written notice at least 30 days in advance, the original certificate, and a $20 reissuance fee. IDFPR will reject a business name using "medical" or a similar term, because it implies services the salon cannot legally provide (Section 1175.1305(b)).

Physical facility requirements come from the sanitary standards at Section 1175.115: a safe, adequate supply of continuous hot and cold running water from an approved source (a restroom sink does not count as that source), immediate licensee access to hot and cold running water, ventilation adequate to keep the shop free of excessive heat, steam, vapors, odors, smoke, and fumes, and compliance with building, fire, plumbing, and electrical codes.

Mobile Cosmetology Salons

A "mobile shop or salon" is defined in 225 ILCS 410/1-4 as a self-contained facility that may be moved, towed, or transported from one location to another and in which cosmetology is practiced. It must hold a certificate of registration like any other salon. Section 1175.1305(c) makes one important accommodation: a mobile salon is not required to report the locations where services are provided. It reports the address of its business office, and one certificate of registration may be issued for the business. Every sanitary standard in Section 1175.115 still applies to the mobile unit, and any fixed physical location dedicated to providing services — including kiosks, trailers, and motor vehicles — is separately subject to registration.

Practical Salon Scenarios & State Board Exam Traps

• Exam Trap: The Practical Demonstration Myth: A frequent point of confusion involves questions about live model draping or mannequin cutting "for the board." Illinois does not conduct a practical exam for cosmetologists. Every clinical safety competency is assessed through written scenario items.
• Exam Trap: The Wrong Blueprint: Illinois uses its own CTS examination, not the NIC national cosmetology theory exam. If a study source describes the exam as four NIC-style domains led by "Hair Care and Services," it is describing the NIC test. Since October 1, 2026 the Illinois outline has ten areas led by Safety and Infection Control (30%), and the exam has 110 questions (100 scored).
• Exam Trap: Apprenticeship Hours and Their Start Date: The Illinois apprenticeship route requires 3,000 hours of practical training plus 180 hours of supplemental instruction — twice the school program's 1,500 hours — but it does not take effect until January 1, 2027 under Public Act 104-478. Today, graduation from a licensed school is the qualifying pathway.
• Salon Scenario: License Hung at the Chair: An inspector enters a salon and finds an operator's current license taped neatly to the mirror at her styling station at the back of the room, where waiting clients cannot see it, and no Department sign anywhere. Section 1-10 is not satisfied. The license and the IDFPR sign must both be prominently displayed where clients enter or wait.
• Salon Scenario: The Post-Pass Clock: A graduate passes the examination in March and then takes a year off before applying to IDFPR. Under the amended 225 ILCS 410/4-5(e) her result still stands — the statutory window is now 3 years — but Part 1175 still reads 12 months, so the safe practice is to file with IDFPR as soon as the CTS results letter arrives.