Illinois licensed community association managers in 2010. New York's equivalent bill has never moved.

Illinois has required a license to manage a condominium, cooperative, or common-interest community association since 2010. When the statute's built-in sunset provision threatened to end that requirement on January 1, 2027, the 2026 legislature passed a bill extending the program through January 1, 2032. New York Senate Bill S.71, which would create a registration requirement for managing agents in New York, was referred to the Judiciary Committee on January 8, 2025. It remained there when Albany adjourned on June 18, 2026, without a hearing scheduled or a vote recorded in either chamber. This is the tenth consecutive session that result has repeated.

What the Illinois statute requires from a community manager.

The Illinois Community Association Manager Licensing and Disciplinary Act, codified at 225 ILCS 427, was enacted under Public Act 096-0726. The law defines "community association management" and prohibits anyone from performing those services for a common-interest community without a license from the Illinois Department of Financial and Professional Regulation (IDFPR).

To obtain a license, a manager must: complete at least 20 hours of pre-license education in community association management within the 24 months before the examination; pass a state-approved examination, the Certified Manager of Community Associations (CMCA) credential or an equivalent; submit a $300 application fee; and be at least 18 years old with a high school diploma or equivalent. Management firms that employ licensed managers must separately register with IDFPR as community association management companies.

Once licensed, a manager must complete 12 hours of continuing education in each two-year renewal cycle. Licenses expire on August 31 of odd-numbered years. The renewal fee is $300. The 12-hour requirement covers topics including association governance, financial management, and applicable state law, with IDFPR specifying approved education sponsors.

The act also created the Community Association Manager Licensing and Disciplinary Board inside IDFPR. The Board has authority to refuse, suspend, or revoke a license for fraud, negligence, misrepresentation, or conduct that endangers residents. A disciplinary record is a public record. That accountability mechanism separates licensing from mere registration: a manager with a history of misappropriating reserve funds or falsifying compliance filings can lose the credential they need to practice, and the record of that loss is searchable.

The 2027 sunset that the 2026 legislature renewed.

Like many Illinois occupational licensing statutes, 225 ILCS 427 contains a sunset provision. Without affirmative legislative action to extend it, the entire framework would have been repealed on January 1, 2027. After that date, no license requirement would have existed, the Disciplinary Board would have lost authority, and managers who obtained licenses would have had no obligation to maintain them.

The 2026 Illinois spring session, which the 104th General Assembly adjourned on May 31, addressed this. The legislature passed a bill extending the sunset from January 1, 2027, to January 1, 2032. According to the Community Associations Institute Illinois Legislative Action Committee's 2026 end-of-session report, the extension passed both chambers and was awaiting Governor action at adjournment. The CAI Illinois chapter represents approximately 3,900,000 Illinoisans living in 1,550,000 homes in more than 20,000 community associations statewide.

This is not the first sunset extension. A prior bill moved the repeal date from 2022 to 2027. Each extension reflects an affirmative legislative vote to keep the licensing regime in place. A legislature deciding, more than once, to maintain manager oversight stands in contrast to a legislature that has not moved a first-version registration bill to a hearing in ten sessions.

What the New York bill contains and where it sits.

S.71, sponsored by Senator Brian Kavanagh, would amend the Real Property Law to require that anyone performing residential realty management for a condo or co-op with 25 or more units file a registration statement with the Secretary of State and demonstrate that they hold an approved certification. Similar versions of the bill have been introduced since at least 2014. No version has received a committee hearing. No version has received a floor vote in either chamber. There is no Assembly companion bill in the current session.

For context on what S.71's absence means in practice: New York Real Property Law imposes no requirement on a managing agent to hold any credential, complete any training, or register with any state body. Nothing in state law prevents a managing agent from moving between buildings after a legal dispute, a financial irregularity, or a failed compliance filing. A license, once revoked in Illinois, follows the manager as a public record. In New York, there is no license to revoke and no public record to follow.

That gap has a direct connection to the Local Law 58 of 2026 enrolled this year: the law made managing agents directly liable alongside co-op boards for timely processing of purchase applications, and extended HPD enforcement authority to reach them. The legislature found it appropriate to make agents liable for a new obligation while leaving in place the condition that agents need no license to take on that liability.

A side-by-side on what each state requires.

The scale of the gap in New York.

CCNYC's building universe covers 15,108 condo and co-op buildings in New York City, representing 10,882 condos and 4,226 co-ops. Every one of those buildings contracts with or employs managing agents who operate without any state-issued credential. The boards that hire them have no public licensing database to consult, no agency to contact when a manager's conduct raises questions, and no licensing body to file a formal complaint with.

The practical result is that accountability for managing-agent conduct in New York runs entirely through private litigation. A co-op shareholder or condo unit owner who believes their agent misdirected reserve funds, falsified vendor invoices, or neglected compliance deadlines must initiate a civil proceeding, at attorney costs that typically run between $250 and $400 per hour, with no administrative alternative. Illinois owners whose manager holds an IDFPR license have a second path: the Disciplinary Board.

What the Illinois model does not do.

The Illinois licensing regime is a credentialing and disciplinary system, not a governance enforcement mechanism. The IDFPR Disciplinary Board can act on professional misconduct: fraud, negligence, misrepresentation, conduct that endangers residents. It does not mediate common-charge disputes, order boards to produce financial records, or step into conflicts between unit owners and elected board members. Those governance disputes in Illinois, as in New York, remain the province of civil courts.

That distinction matters when comparing the two states. Illinois has the licensing layer that New York lacks. Neither state has the owner-dispute ombudsman that Nevada has operated since 1997 or the structural-inspection disclosure regime that Florida enacted after Surfside. The structural incapacity of the NY Attorney General to address governance disputes is a separate gap, diagnosed in a separate post. Licensing is one layer of a governance stack. Illinois chose to build it. New York has not.

Bottom line.

Illinois enacted manager licensing for common-interest communities in 2010 and has now renewed it twice. The 2026 legislature chose, by affirmative vote, to extend a licensing requirement through 2032 rather than let it expire. New York Senate Bill S.71 would create something less demanding than Illinois's framework: registration, not full licensure, with no Disciplinary Board proposed. That bill has spent ten consecutive sessions in committee without a hearing. Virginia licensed managers in 2008. Nevada certified them in 2005. New Jersey mandated reserve studies in 2024. Illinois built a disciplinary board in 2010. None of those steps required a novel idea. Each one required a legislature to schedule a vote. If you want to prompt your representative to schedule a hearing on S.71, the CCNYC letter-to-representative tool provides a structured template with the relevant statutory citations.

Primary sources: 225 ILCS 427 / Community Association Manager Licensing and Disciplinary Act (Illinois General Assembly) · IDFPR Community Association Management · CAI Illinois 2026 End-of-Legislative-Session Report · NY Senate S.71 (2025–2026, Kavanagh)

Companion resources: Nevada certified community managers in 2005. New York has neither. · Virginia licensed condo managers in 2008. New York still hasn't. · S.71: the NY managing-agent licensure bill · When Albany adjourned in June, four co-op reform bills had no vote · NYC just made managing agents liable. They still need no license. · Why the NY AG can't help with condo governance disputes · Issue: Managing agent licensure gap · Issue: No public managing agent registry · Write to your NY representative about S.71 →