When the law becomes effective, Illinois will impose a 0.2% tax on the value of digital assets exchanged, transferred or stored by customers in the state. The tax will be borne by customers and will be collected by brokers that have either a physical presence in the state or $100,000 or more in Illinois gross receipts, according to the commentary.

Registration is required as of Jan. 1, 2027, even for those who have not met the tax collection threshold, per the commentary.

“Brokers with any Illinois exposure should prepare for registration now and review their recordkeeping because Illinois will presume all receipts are in-state unless the broker proves otherwise,” Jones Day said in the commentary. “Registration is required before a broker conducts any digital asset transaction with an Illinois customer, not after hitting the $100,000 threshold.”