Parents across New Trier Township now have a new tool if their child is targeted by an AI-generated fake image or video at school. But the four school districts serving those families must update their bullying policies before students return August 19 — a window of roughly six weeks from the law's effective date.

Illinois House Bill 3851 took effect July 1, expanding the state's cyberbullying definition to cover "unauthorized digital replicas" — AI-generated or digitally altered images, video, or audio depicting a real person without their consent. The law, signed by Gov. JB Pritzker in August 2025, amends the section of the Illinois School Code (105 ILCS 5/27-23.7) that requires every district to maintain a bullying prevention policy.

New Trier Township High School District 203, which serves roughly 4,000 students at its Winnetka Avenue campus, opens the 2026-27 school year August 19. Wilmette District 39, Winnetka District 36, and Kenilworth District 38 face similar timelines. Each must now ensure its written policies explicitly address AI-generated content.

None of the four districts has publicly confirmed whether it has already updated its policies to comply with the new law. North Shore Weekly contacted each district's administration; none had responded as of July 6.

What the law does

Before July 1, a district's bullying policy could reasonably have treated an AI-generated, non-consensual depiction of a classmate as outside the cyberbullying definition, since that definition was written before generative AI tools were widely accessible to students.

HB 3851 closes that gap. A digital replica now counts as cyberbullying if its posting or distribution meets the statute's existing standard — meaning it interferes with a student's education, places a student in reasonable fear of harm, or creates a hostile school environment. The law borrows its definition of "digital replica" from the Digital Voice and Likeness Protection Act.

Consensual use of AI in the classroom, such as approved class assignments, is explicitly excluded.

No state template yet

The Illinois State Board of Education was required to develop statewide guidance by July 1. It missed that deadline. ISBE press secretary Lindsay Record confirmed the agency is still working on it, adding that "local policies, procedures and responses to specific incidents are determined at the district and school level."

That means North Shore districts are writing their own policy language without a state model to follow.

Districts that fail to meet the updated policy and reporting requirements will be ineligible for grants from the Illinois Bullying and Cyberbullying Prevention Fund, according to the law's text.

Why it matters on the North Shore

A 2024 Center for Democracy & Technology survey found that 40% of K-12 students were aware of a deepfake involving someone at their school. Fifteen percent knew of a sexually explicit deepfake depicting a member of their school community. More than 60% of teachers reported their school had not shared policies or procedures related to AI-generated sexual imagery.

Earlier in 2026, administrators at Lake Zurich High School — about 20 miles northwest of Winnetka — confronted students using AI to create sexually explicit images of classmates and reported the matter to police.

Debra Jacobson, general counsel of the Illinois Association of School Boards, described the challenge facing districts statewide as "a bit of a game of Whac-A-Mole, just because the technology is evolving very quickly," in comments reported by Shaw Local News Network.

What parents can do

Families can now report AI-generated, unauthorized depictions of a student to their school and have the complaint evaluated under the same cyberbullying framework used for other online harassment. They also retain the option to report to law enforcement if the conduct may independently violate Illinois' criminal deepfake or nonconsensual-image statutes, which can carry felony charges.

Parents who want to review their district's current bullying prevention policy or request draft policy documents being prepared for the new school year can file a Freedom of Information Act request (5 ILCS 140) with their district's administration office.

The law was sponsored in the House by Rep. Janet Yang Rohr (D-Naperville) and advanced through the Senate by Sen. Meg Loughran Cappel (D-Shorewood).