The Illinois Open Meetings Act (OMA) establishes requirements for how public bodies conduct business and provide notice to the public. Your municipal website plays a crucial role in meeting these requirements. This guide covers how Illinois municipalities can leverage their websites for OMA compliance while improving transparency.
Understanding the Open Meetings Act
The Illinois Open Meetings Act (5 ILCS 120/) applies to all public bodies in Illinois, including:
- Cities and villages
- Townships
- Counties
- School districts
- Park districts
- Library districts
- Other governmental bodies
The Act requires that public business be conducted openly, with adequate notice to allow public participation.
Key OMA Requirements
Understanding your obligations is the first step to compliance.
Meeting Notice Requirements
Regular Meetings:
- Annual schedule must be provided at the beginning of each calendar/fiscal year
- Schedule must include dates, times, and places of regular meetings
- Posting location for notice of other meetings must be stated
Special Meetings:
- At least 48 hours' notice required
- Notice must be posted at the principal office of the public body
- Notice must include agenda
- Personal notice required for media who have filed annual requests
Emergency Meetings:
- May be held with less than 48 hours' notice when necessary due to bona fide emergency
- Still requires best notice practicable
- Minutes must state reasons for emergency
Reconvened/Rescheduled Meetings:
- Public notice required at least 48 hours in advance
- Same notice requirements as special meetings
Agenda Requirements
Agendas must be:
- Posted at least 48 hours before the meeting
- Sufficiently descriptive to inform public of business to be conducted
- Available for public inspection
Agenda Specificity: Items must be described with enough detail that the public understands what will be discussed. Generic items like "New Business" don't satisfy the requirement for action items.
Minutes Requirements
Content:
- Date, time, and place of meeting
- Members present and absent
- Summary of discussion on all matters
- Record of all votes
Timing:
- Must be approved within 30 days (or at second subsequent regular meeting if meetings are less than monthly)
- Must be available for public inspection within 10 days of approval
Accessibility:
- Must be available for public inspection and copying
- Closed session minutes have separate requirements
Closed Sessions
Closed sessions are permitted only for specific purposes listed in the Act. Requirements include:
- Must be recorded (audio or video)
- Must keep minutes
- Semi-annual review of closed session minutes
- Majority roll call vote to close meeting
Website Posting Requirements
Illinois law has evolved to address electronic posting.
What Must Be Posted Online
If you maintain a website, you must post:
- Annual meeting schedule
- Agenda for each meeting (at least 48 hours in advance)
- Meeting notices for special meetings
Best Practice: Also post:
- Approved minutes
- Meeting recordings (if created)
- Supporting materials/packet
Where to Post
The Public Access Counselor has issued guidance that website posting should be:
- Easily accessible (not buried deep in site navigation)
- Consistently located (same place for all notices)
- Searchable (if practical)
Timing Requirements
48-Hour Rule: Agendas must be posted at least 48 hours before meeting time.
Documentation: Maintain records of when items were posted—timestamped logs can be important if posting is challenged.
Physical Posting Remains Required
Website posting supplements but does not replace physical posting at:
- Principal office of the public body
- Meeting location (if different)
Both physical and website posting are required.
Building OMA-Compliant Website Features
Your website can make compliance easier and more transparent.
Meeting Portal
Create a centralized meeting section that includes:
Annual Calendar:
- All regular meeting dates
- Meeting bodies covered
- Times and locations
- Downloadable calendar
Meeting Pages:
- Individual page for each meeting
- Agenda posted with timestamp visible
- Packet/supporting materials
- Minutes (after approval)
- Recording links
Navigation:
- Easy to find from homepage
- Clear organization by body
- Historical archive accessible
For implementation guidance, see our guide on publishing agendas and minutes online.
Automated Posting Tools
Reduce compliance risk with automation:
Scheduled Publishing: Queue agendas to publish at specific times with verification.
Timestamp Logging: Automatic recording of publication dates/times.
Email Integration: Automatic notice to registered media upon posting.
Checklist Systems: Ensure all required elements are included before posting.
Subscription System
Allow residents and media to subscribe to:
- All meeting notices
- Notices for specific bodies
- Agenda postings
- Minutes availability
This supports the spirit of transparency beyond minimum requirements.
Archive and Search
Comprehensive archives serve:
- Public transparency
- FOIA request reduction
- Historical research
- Legal documentation
Archive Features:
- All past agendas and minutes
- Search by date range
- Search by meeting body
- Keyword search within documents
- Accessible document formats
Document Accessibility
OMA compliance intersects with accessibility requirements.
Accessible Formats
All posted documents must be accessible:
Agendas and Minutes:
- Proper heading structure
- Readable by screen readers
- Adequate color contrast
- Searchable text (not scanned images)
Recordings:
- Captions for video
- Transcripts for audio
- Accessible player controls
Document Preparation
Staff creating meeting documents should:
- Use word processor heading styles
- Export to accessible PDF
- Check accessibility before posting
- Avoid scanned-image documents
For detailed guidance, see our article on accessibility mistakes on government websites.
Common OMA Website Mistakes
Avoid these pitfalls:
Posting Too Late
Problem: Agenda posted less than 48 hours before meeting.
Risk: OMA violation; action taken at meeting could be challenged.
Solution: Build buffer time; set internal deadline earlier than required; use automated scheduling.
Insufficient Agenda Detail
Problem: Vague agenda items like "Old Business" or "New Business" without specifics.
Risk: Public not informed of business to be conducted.
Solution: Describe each action item specifically; train staff on requirements.
Inaccessible Documents
Problem: Scanned PDFs or documents without proper structure.
Risk: ADA compliance issues; exclusion of residents with disabilities.
Solution: Create native digital documents; add accessibility features; test with screen readers.
Difficult Navigation
Problem: Meeting information buried deep in website structure.
Risk: Not meeting "easily accessible" expectation.
Solution: Prominent "Meetings" link in navigation; direct links from homepage.
Missing Historical Records
Problem: Only recent meetings available; older records purged.
Risk: Reduced transparency; FOIA burden increased.
Solution: Maintain comprehensive archive; plan for long-term storage.
No Posting Documentation
Problem: No record of when documents were posted.
Risk: Cannot prove compliance if challenged.
Solution: Automated timestamps; posting logs; regular audits.
FOIA Intersection
The Freedom of Information Act (5 ILCS 140/) relates to OMA compliance.
Proactive Posting Reduces FOIA
When meeting documents are readily available online:
- Fewer FOIA requests for routine records
- Faster response when requests are made
- Demonstration of transparency commitment
FOIA-Friendly Practices
- Searchable document archives
- Consistent file naming
- Metadata preservation
- Historical record retention
Working With the Public Access Counselor
The Illinois Attorney General's Public Access Counselor provides guidance and handles complaints.
Binding Opinions
The PAC issues binding opinions on OMA questions. Review recent opinions relevant to:
- Website posting requirements
- Agenda specificity
- Emergency meeting procedures
- Closed session requirements
Request for Review
If you receive a Request for Review (complaint), having documented website practices helps demonstrate compliance.
Advisory Opinions
You can request advisory opinions on compliance questions before issues arise.
Best Practices Beyond Minimum Compliance
Excellent municipalities go beyond minimum requirements:
Live Streaming
Provide real-time access to meetings:
- Video streaming when possible
- Audio when video isn't feasible
- Archive recordings after meetings
Interactive Participation
Enable remote public comment:
- Registration systems
- Speaking time management
- Written comment submission
Enhanced Notice
Additional notification methods:
- Social media announcements
- Email newsletters
- Text alerts for specific topics
Packet Availability
Post complete meeting materials:
- Staff reports
- Supporting documentation
- Presentations
- Correspondence
Meeting Summaries
Accessible summaries for residents:
- Key decisions highlighted
- Plain language explanations
- Links to detailed minutes
Implementation Checklist
Use this checklist to evaluate your OMA compliance:
Annual Requirements:
- [ ] Annual meeting schedule posted
- [ ] Schedule includes all required information
- [ ] Schedule posted at beginning of year
Each Meeting:
- [ ] Agenda posted 48+ hours in advance
- [ ] Agenda has sufficient detail
- [ ] Physical posting completed
- [ ] Website posting completed
- [ ] Posting time documented
After Meeting:
- [ ] Minutes prepared
- [ ] Minutes approved timely
- [ ] Approved minutes posted within 10 days
- [ ] Recording available (if made)
Accessibility:
- [ ] Documents are screen-reader accessible
- [ ] Videos have captions
- [ ] Site navigation works without mouse
Documentation:
- [ ] Posting times recorded
- [ ] Archive maintained
- [ ] Retention schedule followed
Website Design for OMA Compliance
When designing or redesigning your municipal website, build OMA compliance into the structure:
Navigation: Prominent "Meetings" or "Agendas & Minutes" section accessible from all pages.
Content Types: Structured meeting and document content types in your CMS.
Workflow: Publishing workflows that enforce notice timing requirements.
Automation: Scheduled publishing, timestamp logging, notification systems.
Archives: Scalable storage for growing historical records.
Getting Help
OMA compliance can be complex. Resources include:
Illinois Attorney General: Public Access Counselor guidance and opinions.
Illinois Municipal League: Training and resources for member municipalities.
Municipal Attorneys: Legal advice on specific situations.
Website Partners: Technical implementation support.
At CivicSitePro, we build Illinois municipal websites with OMA compliance in mind. Our solutions include meeting portals, automated posting systems, and accessible document management.
Need help ensuring your website supports OMA compliance? Request a free audit to evaluate your current setup, or book a consultation to discuss your compliance needs.