Illinois splits dental oversight across more agencies than most owners expect. Your license comes from one department, your x-ray machines answer to a completely different one, your amalgam wastewater is governed by a federal rule enforced by whoever runs your sewer system, and your non-compete is governed by a state employment statute that has nothing to do with dentistry. This page tells you which door to knock on for each question, and gives you the handful of facts we could confirm directly from the agencies' own pages in September 2026.
Key takeaways
- Licensure and continuing education sit with the Illinois Department of Financial and Professional Regulation (IDFPR). The rule sets 48 CE hours for dentists and 36 for dental hygienists, measured over the 36 months before September 30 of the renewal year.
- X-ray machines are registered with IEMA-OHS (the Illinois Emergency Management Agency and Office of Homeland Security), not with IDFPR. Registration is annual and equipment additions or removals have to be reported.
- Illinois is one of the few states with a hard statutory floor on non-competes. Under the Illinois Freedom to Work Act, a non-compete is void for anyone earning $75,000 or less, and a non-solicit is void at $45,000 or less. Those thresholds step up on January 1, 2027.
- There is no state amalgam separator rule to look up. The federal EPA dental rule applies, and the entity that enforces it against your office is your pretreatment control authority, usually the local sewer district.
Rules change. Every item below was checked against an official Illinois or federal source in September 2026, and fee amounts, deadlines and CE rules change without much warning. Confirm with the agency directly before you act on anything here.
Who regulates what
| Topic | Agency | Official link |
|---|---|---|
| Dentist and hygienist licensure | Illinois Department of Financial and Professional Regulation, Division of Professional Regulation | IDFPR Dental Professions |
| Dental hygiene and dental assistant scope | Illinois Dental Practice Act (225 ILCS 25) and 68 Ill. Adm. Code 1220 | Section 1220.245, Prescribed Duties of Dental Assistants |
| X-ray machine registration and fees | IEMA-OHS, Division of Nuclear Safety | Annual X-Ray Equipment Registration |
| Adding, moving or removing an x-ray machine | IEMA-OHS, Division of Nuclear Safety | New Registration / Change of Name / Address / Equipment |
| Radiographic operator requirements | IDFPR under the Dental Practice Act (dental assistants may expose films under supervision) | 225 ILCS 25/17 |
| Infection control in the dental office | IDFPR and the Illinois Board of Dentistry (plus federal OSHA) | Illinois Board of Dentistry |
| Amalgam separators and dental wastewater | US EPA rule, enforced through your local pretreatment control authority | EPA Dental Effluent Guidelines |
| Corporate practice and practice ownership | Illinois Dental Practice Act plus entity filings with the Illinois Secretary of State | Illinois Dental Practice Act |
| Sales and use tax on equipment | Illinois Department of Revenue | Illinois Department of Revenue |
License renewal and continuing education
IDFPR handles renewal through its online system, and the department moved dental renewals onto a new licensing platform in late 2024. The renewal portal and instructions are linked from the Dental Professions page.
The continuing education requirement is set in rule, not on a web page, which is why it is worth reading the rule directly. Section 1220.440 of Title 68 of the Illinois Administrative Code requires 48 hours of CE relevant to the practice of dentistry for dentists and 36 hours relevant to the practice of dental hygiene for hygienists. The rule measures those hours over the 36 months preceding September 30 of the renewal year, which is the detail most CE trackers get wrong. IDFPR's own CE guidance form repeats the 48 and 36 hour figures and confirms that coursework has to fall in the prerenewal period.
What counts is narrower than people assume. The rule limits credit to clinical coursework in dentistry or dental hygiene, plus nonclinical subjects that directly support clinical services, such as patient management, legal and ethical responsibilities, and stress management. Estate planning, financial planning and investment courses are explicitly excluded. If you are buying CE at a trade show because it is cheap, check the subject matter against that list before you pay.
September 30 is the date to build your calendar around. Confirm your own expiration date on your license record rather than assuming, because initial licenses issued mid-cycle do not always line up with the standard pattern.
X-ray equipment: registration and inspection
Illinois x-ray registration lives with IEMA-OHS, which runs the state's radiation safety program. This surprises people who assume the dental board handles it, and it is the single most common compliance gap we see when a practice changes hands.
The mechanics that IEMA-OHS publishes:
- Registration is annual, with a fee paid per facility. The agency runs an online facility inventory system where existing registrants update equipment and pay.
- A brand new facility has to file a paper registration form first in order to be issued a facility registration number. You cannot start in the online system from scratch.
- Any change of facility name, change of address, or addition or removal of equipment has to be reported to the agency. The agency accepts the registration form by mail, and takes questions by email, phone and fax.
IEMA-OHS does not publish its inspection interval or its fee schedule on the registration landing page, so treat both as items to confirm by phone or email before you budget for them. The agency also publishes periodic information notices to x-ray facilities and to radiation machine service providers, which are worth reading if you are planning an installation or a relocation.
On who may push the button: the Illinois Dental Practice Act permits dental assistants to use x-ray machines for exposing films under a dentist's supervision. The Act itself does not spell out a prerequisite training course inside that subsection, and the dental assistant duties rule does not address radiography. Illinois does not publish this clearly in one place, so confirm the current training expectation directly with IDFPR before you put a new assistant behind a sensor.
For the general mechanics that apply in every state, see our guide to dental x-ray registration and inspections.
Buying and selling used equipment in Illinois
Three things follow the equipment rather than the dentist, and all three are easy to miss in a transition.
X-ray registration does not travel with the box
If you buy a used intraoral unit, pan or CBCT and install it at your address, that is an equipment addition at your facility and it has to be reported to IEMA-OHS. If you sell or scrap a unit, that is an equipment removal, and if you do not report it you keep paying registration fees on a machine you no longer own. Sellers should not assume the buyer's paperwork closes out their own registration. File the change on both ends.
Relocating the whole practice is a change of address, which is its own filing. Do it before the first patient is imaged at the new address, not after.
Amalgam separators and wastewater
Illinois has no separate state separator rule for you to chase. The federal EPA dental effluent rule applies to dental dischargers that place or remove amalgam and send wastewater to a publicly owned treatment works. It requires an amalgam separator that meets the standard, plus best management practices: do not flush scrap amalgam, and do not use bleach or other oxidizing line cleaners that dissolve mercury. It also requires a one-time compliance report filed with your pretreatment control authority, which is usually your local sewer utility.
The practical point for a transition: a change in ownership is exactly the moment your control authority may want a new report on file. EPA's own page does not spell out how ownership changes are handled, so call your sewer district and ask what they expect from the incoming owner. If you are replacing a separator during a remodel, our guide to amalgam separators covers sizing, installation and recycling records.
Lead, chemicals and old film processing
If you are clearing out a room that used to house a film processor, you are dealing with lead foil, lead aprons, spent fixer and developer, and sometimes a lead-lined cabinet. None of that belongs in the dumpster. Work through a licensed waste vendor and keep the manifests, since they are the only proof you handled it correctly. Our overview of dental waste disposal walks through each stream.
Before you wire money on a used unit, run the pre-purchase equipment checklist and read up on the hidden costs of buying used, which in Illinois includes the registration and inspection tail on imaging.
Non-competes and employment
Illinois is unusual because it puts a hard number in statute. The Illinois Freedom to Work Act (820 ILCS 90) makes a covenant not to compete void and unenforceable for a worker whose actual or expected annual earnings do not exceed $75,000. A covenant not to solicit is void at $45,000 or less. Those thresholds rise on January 1, 2027 to $80,000 and $47,500, again on January 1, 2032 to $85,000 and $50,000, and again on January 1, 2037 to $90,000 and $52,500.
In a dental office this cuts both ways. An associate dentist will almost always earn above the non-compete threshold, so the statutory floor will not save them, and the agreement gets judged on the rest of the Act and on Illinois case law. Hygienists, assistants and front office staff frequently fall below the non-solicit threshold, which means restrictive language in their handbooks or offer letters may be unenforceable on its face.
The Act also carries procedural requirements around adequate consideration, advance notice, and telling the worker to consult an attorney before signing. Those are the kind of technical requirements that sink otherwise reasonable agreements, so have a lawyer draft or review the template you hand to every new hire rather than reusing something from another state.
At the federal level, the FTC's non-compete rule is not in effect. The Commission voted on September 5, 2025 to dismiss its appeals and accede to the court decisions vacating the rule, so state law governs. Our national overview of non-compete agreements for dentists covers how these clauses are typically drafted, but the specific application to your contract is a question for an Illinois employment attorney.
What we could not confirm
- The current IEMA-OHS x-ray registration fee schedule and the deadline for annual payment. The agency does not publish either on the registration landing page.
- How often Illinois inspects dental x-ray facilities. The agency does not publish an interval.
- The exact training a dental assistant must complete before exposing radiographs. The Dental Practice Act allows the task under supervision but the board does not publish a clear prerequisite in the sections we read. Confirm directly with IDFPR.
- Whether Illinois exempts dental equipment from sales or use tax in any circumstance. Confirm with the Illinois Department of Revenue and your CPA, especially on private-party purchases where use tax is the usual trap.
- The precise limits Illinois places on non-dentist ownership of a dental practice. Read the Dental Practice Act with a dental-specific attorney before structuring anything.
Where to verify
- Illinois Department of Financial and Professional Regulation: Dental Professions and the Board of Dentistry
- Illinois General Assembly, Joint Committee on Administrative Rules: 68 Ill. Adm. Code 1220.440, continuing education
- Illinois General Assembly: 225 ILCS 25/17, dental assistant duties and 820 ILCS 90/10, Illinois Freedom to Work Act
- IEMA-OHS Division of Nuclear Safety: annual x-ray registration and new registration and equipment changes
- US Environmental Protection Agency: dental effluent guidelines, 40 CFR Part 441
- Federal Trade Commission: September 2025 statement acceding to vacatur of the non-compete rule
- Illinois Department of Revenue: tax.illinois.gov
Putting it to work
If you are buying a practice in Illinois, add three line items to your due diligence list that nobody will hand you: a current IEMA-OHS facility registration printout with the equipment inventory, the one-time EPA amalgam compliance report on file with the sewer district, and every employment agreement with a restrictive covenant so counsel can test it against the Freedom to Work Act thresholds. If you are selling, close out your x-ray registration for anything that leaves the building.
Related reading: our national guide to x-ray registration and inspections, the pre-purchase equipment checklist, and the compliance chapter in the practice operations guide. You can also browse the rest of the state resources directory.
This guide is educational content and does not constitute legal, financial, tax, or clinical advice. Laws and regulations vary by state and change over time. Consult your own dental-specific attorney, CPA, and state dental board before acting.