A property management company oversees a mixed portfolio across Chicagoland - units in the city and units in Skokie, Oak Park, and Berwyn. The team follows Chicago RLTO procedures: the lease disclosures, the security deposit handling, the entry notice requirements. For the Chicago units, that compliance is correct. For the suburban Cook County units, it may not be.

The Cook County Residential Tenant and Landlord Ordinance (RTLO) is an entirely separate local law - not a version of the Chicago RLTO and not Illinois state law. It was passed unanimously by the Cook County Board of Commissioners in January 2021 and took effect June 1, 2021. It generally governs residential tenancies across suburban Cook County outside Chicago's city limits, subject to municipalities that have adopted their own landlord-tenant ordinances. It has its own required disclosures, its own security deposit rules, its own entry notice standards, its own late fee caps, and its own tenant remedy structure. Property managers who assume the Chicago RLTO and the Cook County RTLO are interchangeable risk applying the wrong compliance requirements to suburban units.

This guide covers every material requirement of the Cook County RTLO - who is covered, what must be disclosed, how security deposits must be handled, when and how a landlord may enter, what late fees are permissible, and what tenant remedies attach to each violation.

Cook County RTLO vs. Chicago RLTO: These Are Different Legal Frameworks

Property managers with mixed portfolios must track both ordinances independently. Operating a suburban Cook County unit as though the Chicago RLTO applies - or vice versa - can create compliance issues because the two ordinances contain different requirements.

What the Cook County RTLO Is - and Where It Applies

The Cook County RTLO is codified in Article VIII of the Cook County Code of Ordinances (Sections 42-800 through 42-813). It was passed on January 26-28, 2021, and became effective June 1, 2021, with the anti-lockout provision (Section 42-813) taking effect immediately upon enactment.

The RTLO generally applies throughout suburban Cook County outside Chicago unless a municipality has adopted its own ordinance governing the landlord-tenant relationship.

The municipal preemption rule is important. The Cook County RTLO expressly defers to municipalities that already have their own ordinances specifically regulating the landlord-tenant relationship. Some municipalities within suburban Cook County maintain their own landlord-tenant ordinances that supersede portions of the county RTLO. Property managers should verify whether a specific municipality has its own ordinance - and review the Cook County official RTLO guidance - before assuming the county-level RTLO controls.

Chicago properties are governed by the Chicago Residential Landlord and Tenant Ordinance (RLTO), which has been in effect since 1986 and is entirely separate from the Cook County RTLO.

Enforcement. The RTLO is enforced through individual right of action - meaning violations are pursued through civil lawsuits, not through a government enforcement agency. The Cook County Commission on Human Rights explicitly states it is not an enforcement agency for the RTLO. Compliance failures create direct civil liability for landlords.

Must Read: Illinois Security Deposit Law: Interest Rules, Timelines, and Penalties

Who Is Covered and Who Is Exempt

The Cook County RTLO covers most residential rental units in suburban Cook County, including mobile homes and subsidized housing. It applies regardless of the duration of the tenancy.

Units exempt from the RTLO (except for the anti-lockout provision, which has no exemptions) :

• Owner-occupied buildings with six or fewer units - the "mom and pop" exemption. If the building owner lives in the same building and it has six or fewer rental units, the RTLO does not apply.

• Single-family homes and single condominium units where: (1) the owner is only renting that one rental property, and (2) the owner or an immediate family member has lived in the home within the past 12 months. Both conditions must be met.

• Hotels, motels, and rooming houses - unless rent is paid on a monthly basis and the unit has been occupied for more than 32 days.

• Dormitories, shelters, employees' quarters, and non-residential rental properties.

• Owner-occupied co-ops and single room occupancy housing serving vulnerable residents.

If a landlord claims exemption, they must notify the prospective tenant in writing of the exemption before accepting any fees.

For property management portfolios operating across multiple suburban Cook County municipalities, RIOO's lease management workflows support per-unit configuration to track which properties are subject to the RTLO and which fall under municipal or exemption frameworks.

The RTLO Summary : The Required Lease Attachment

The most foundational compliance obligation under the Cook County RTLO is one that many landlords overlook entirely: every lease for a covered unit must have the Cook County RTLO summary attached.

The Cook County Commission on Human Rights publishes an official RTLO summary in English, Spanish, and Polish. A copy of this summary must be provided to every tenant before or at lease signing.

The RTLO includes a narrow landlord cure right specifically for this requirement. If the landlord fails to attach the ordinance summary and the tenant wants to break the lease on that basis, the landlord has two business days to provide the most recent copy of the summary. This cure right also applies to other administrative errors - including failure to disclose authorized entrants and ownership transfer, and failure to disclose the name of the financial institution holding the security deposit.

Required Disclosures: What Must Be Provided Before Signing

The Cook County RTLO requires specific written disclosures to the tenant before a rental agreement is entered into or renewed. Under Section 42-810(C), the landlord must disclose:

1. Code violations
Any code violations cited by the municipality or other oversight body during the previous 12 months for the dwelling unit and common areas, including case numbers for any code enforcement proceedings.

2. Pending utility termination notices
Any notice of intent by the municipality or a utility provider to terminate water, gas, electrical, or other utility service to the unit or common areas.

3. Foreclosure proceedings
If the property is subject to litigation seeking foreclosure, this must be disclosed.

4. Owner and manager contact information
The landlord must disclose the owner's name, address, and telephone number, including during ownership transfers.

5. Financial institution for security deposit
The name of the Illinois financial institution where the security deposit will be held must be disclosed in the rental agreement.

The penalty for failing to disclose code violations is particularly significant. This is a strict liability provision with no cure right. If a landlord fails to disclose code violations before a lease is entered into or renewed, the tenant may terminate the rental agreement by written notice specifying a termination date no later than 30 days from the date of written notice. The tenant may also recover one month's rent or actual damages, whichever is greater, plus reasonable attorney's fees.

Security Deposit Requirements

Deposit cap  :
The RTLO caps security deposits at 1.5 times the monthly rent. Tenants have an additional six months to pay any portion of the deposit that exceeds one month's rent. For example, if monthly rent is $1,500, the maximum deposit is $2,250 - but the tenant may pay $1,500 upfront and the remaining $750 over the following six months.

Where the deposit must be held :
The security deposit must be held in a financial institution located in the State of Illinois, maintained separately from the landlord's personal accounts. The name of that institution must be disclosed to the tenant in the rental agreement.

Return timeline:

• Immediately: If the tenant vacated after sending a 72-hour demand letter because the landlord failed to repair essential services

• Within 48 hours: If the tenant vacated due to fire or casualty damage, or if the landlord refused to allow the tenant to move in

• Within 30 days: In all other circumstances

The landlord must deliver or mail a detailed statement of deductions within 30 days, with paid receipts or estimates followed by paid receipts within 30 days of the estimate. Landlords have 30 days to determine security deposit deductions, which may include damage repairs and some court costs (but not attorney's fees).

Permissible deductions :
Unpaid rent not validly withheld, court fees awarded in proceedings (but not attorney's fees), and reasonable repair costs for tenant-caused damage - excluding ordinary wear and tear.

Penalty for violation :
Damages equal to twice the security deposit plus attorney's fees. The tenant has two years from the date of the violation to bring a claim.

RIOO's property accounting module supports per-unit deposit tracking with financial institution records and move-out statement documentation - maintaining the records that Cook County RTLO compliance requires.

Landlord Right of Entry

Under Section 42-808(B) of the RTLO, a landlord may enter a covered rental unit if the landlord gives the tenant 2 days' notice. Notice may be delivered by mail, telephone, written notice, or other means designed in good faith to provide notice.

Permitted entry hours : 8:00 a.m. to 8:00 p.m.

Permitted purposes for entry include:

• Making necessary or agreed repairs

• Inspecting the premises

• Showing the unit to prospective tenants or purchasers within 60 days of the lease ending

• Supplying agreed services

Emergency exception. In a genuine emergency, the landlord may enter without advance notice to make emergency repairs.

Tenant consent. The tenant may consent to a shorter notice period.

Also Read: Illinois Eviction Process: Notice Requirements, Filing Steps, and Common Dismissal Reasons

Habitability and Repair Obligations

The Cook County RTLO requires landlords to maintain rental units in compliance with relevant local building codes and to ensure the unit meets minimum habitability standards:

• Essential services.
  Heat, running water, hot water, electricity, gas, plumbing - and internet access if the rental agreement requires the landlord to provide it.

• Adequate heat.
  From September 15 through June 1 of each year, inside temperature must be at least 68 degrees Fahrenheit from 8:30 a.m. to 10:30 p.m., and at least 66 degrees Fahrenheit from 10:30 p.m. to 8:30 a.m.

• Repair timeline.
  When a tenant notifies the landlord of a repair need, the landlord has 14 days to make the necessary repairs. If repairs are not made within 14 days, the RTLO provides tenants with potential remedies that may include repair-and-deduct rights or lease termination in certain circumstances. Tenants are advised to seek legal counsel before exercising these remedies.

• Bed bug obligations.
  The tenant must notify the landlord in writing within 48 hours of seeing bed bugs. After notification, the landlord must provide pest control services within 10 days and must maintain written records of pest control measures for 3 years.

Late Fee Caps

The Cook County RTLO caps late fees at a specific formula:

• $10 per month if monthly rent is $1,000 or less

• $10 plus 5% of the amount over $1,000 per month for rent exceeding $1,000

For a tenant paying $1,500 per month: the maximum late fee is $10 (on the first $1,000) plus $25 (5% of the remaining $500) = $35 per month maximum.

Additionally, the landlord must apply rent payments to rent first - not to other costs such as utilities. Any late fee provision in a lease that exceeds this formula is unenforceable under the RTLO.

Lease Renewal and Non-Renewal Notices

Under the Cook County RTLO, a landlord must give the tenant at least 60 days' notice before the end of the lease term if the landlord does not intend to renew the lease.

The RTLO also contains a reciprocity provision: a landlord cannot require a tenant to provide a longer move-out notice period than the notice the landlord is required to give for non-renewal.

Prohibited Lease Provisions

The Cook County RTLO expressly prohibits certain provisions from being included in any lease for a covered unit. Under Section 42-804, a lease may not:

• Waive notices or require tenants to "confess judgment"

• Waive the tenant's right to receive eviction notices or other required notices

• Waive the tenant's right to a jury trial

• Prevent the tenant from making negative statements about the landlord

• Require the tenant to give a longer notice for moving out than the landlord is required to give for non-renewal

• Require the tenant to pay attorney's fees in an eviction case

• Waive any right provided to the tenant under the RTLO

Penalty for prohibited lease provisions. If a landlord deliberately uses a rental agreement containing any provision known to be prohibited, the tenant may recover actual damages or two months' rent, whichever is greater.

Anti-Lockout Provisions: No Exemptions

Section 42-813 of the Cook County RTLO prohibits lockouts for every residential rental unit in Cook County with no exceptions. This provision was effective immediately upon enactment in January 2021.

A landlord may not:

• Change or remove the locks on a rental unit

• Remove the doors of a rental unit

• Cut off heat, utility, or water service

• Remove the tenant's personal property

• Otherwise interfere with the tenant's use and enjoyment of the unit

A landlord must follow the proper eviction process through court. Only the Cook County Sheriff's office can enforce a court order to evict a tenant. The anti-lockout prohibition applies even when the landlord believes the tenant has abandoned the unit, unless the proper abandonment determination has been made. Under the RTLO, a landlord may determine abandonment only if: the tenant has given written notice of abandonment, OR the tenant has not been present in the unit for 32 days, has removed their property, and has not paid rent.

Common Compliance Failures in Cook County RTLO Practice

1. Failing to attach the RTLO summary to every lease.
The summary must be provided with every lease for a covered unit.

2. Failing to disclose code violations before lease signing.
Strict liability, no cure right. Landlords who skip this face tenant termination rights and damages.

3. Misapplying the single-family home exemption.
The exemption applies only when the owner is renting that one rental property AND the owner or family member resided there within the past 12 months. Owners who hold multiple rental properties cannot claim this exemption.

4. Charging security deposits above 1.5 times monthly rent.
The cap is explicit. Deposits must be held at an Illinois financial institution and the institution name must be disclosed.

5. Entering without 2 days' notice outside of a genuine emergency.
Property managers accustomed to less specific standards regularly underestimate the RTLO's entry notice requirements.

6. Charging late fees that exceed the RTLO cap.
The $10 plus 5% formula is strict. Flat-rate late fee provisions in many standard leases exceed this cap.

7. Including prohibited lease provisions.
Jury trial waivers, confess-judgment clauses, and attorney's fee provisions must be removed from any lease for a covered Cook County unit.

8. Failing to follow bed bug remediation obligations.
Pest control must be arranged within 10 days of notification and written records maintained for 3 years.

Frequently Asked Questions

1. When did the Cook County RTLO take effect?

The Cook County RTLO was passed unanimously on January 26-28, 2021. The anti-lockout provision took effect immediately, and the full ordinance took effect June 1, 2021.

2. Does the Cook County RTLO apply to Chicago properties?

No. Chicago properties are governed by the Chicago RLTO, which has been in effect since 1986 and is entirely separate. Some municipalities within suburban Cook County also maintain their own landlord-tenant ordinances that supersede the county RTLO. Property managers should verify the applicable framework for each municipality.

3. What is the security deposit cap under the Cook County RTLO?

Security deposits are capped at 1.5 times the monthly rent, held at an Illinois financial institution with the institution name disclosed in the lease. Tenants have six months to pay any portion exceeding one month's rent.

4. How long does a Cook County landlord have to return a security deposit?

Generally 30 days. The timeline is shorter in specific circumstances: immediately if the tenant vacated after a 72-hour essential services demand; 48 hours for fire, casualty, or landlord refusal to allow move-in.

5. What happens if a landlord fails to disclose code violations before a lease is signed?

Strict liability with no cure provision. The tenant may terminate the lease by written notice and may recover one month's rent or actual damages, whichever is greater, plus reasonable attorney's fees.

6. Does the anti-lockout provision apply to owner-occupied small buildings?

Yes. The anti-lockout provision under Section 42-813 applies to every residential rental unit in Cook County with no exceptions.

7. What is the maximum late fee under the Cook County RTLO?

$10 per month if rent is $1,000 or less. If rent exceeds $1,000, the maximum is $10 plus 5% of the rent amount over $1,000.

8. How is the Cook County RTLO enforced?

Through individual right of action - civil lawsuits brought by tenants. The Cook County Commission on Human Rights explicitly states it is not an enforcement agency for the RTLO. Violations create direct civil liability for landlords.

Conclusion

The Cook County Residential Tenant and Landlord Ordinance is not a variation of the Chicago RLTO - it is a distinct regulatory framework with its own required disclosures, security deposit rules, entry notice standards, late fee caps, habitability standards, prohibited lease provisions, and tenant remedy structure. For property managers with suburban Cook County portfolios, compliance means understanding the RTLO on its own terms: what it requires, what it prohibits, and what penalties attach to each failure.

Every covered lease needs the RTLO summary attached. Code violations must be disclosed before signing. Deposits must be capped, held at Illinois institutions, and returned within specific timelines. Entry requires two days' notice. Late fees must follow the ordinance formula. Prohibited provisions must be scrubbed from standard lease forms. And the anti-lockout rule has no exceptions anywhere in Cook County.

RIOO supports Cook County property management operations through lease management, property accounting, service request and task management, and workflow and customization tools - helping management teams organise the lease, accounting, service request, and documentation workflows that support RTLO compliance efforts.

Disclaimer : This blog is intended for general informational purposes only and does not constitute legal advice. Cook County RTLO provisions are subject to change, and individual circumstances vary. Property managers should consult a qualified Illinois attorney before making compliance decisions.