Illinois rules
How do Illinois' 2025 rules on lead platforms and directories affect law firm marketing?
Since July 1, 2025, Illinois lawyers who get clients through directories, lead generators or matching sites have to disclose it, check the platform, and avoid fee-share pricing.
By Santiago Alvarez, Founder, Ad Hoc Digital
Last updated
The short answer
If you read one part of this page, read this.
Since July 1, 2025, Illinois Rule 7.2(c) lets lawyers use and pay "intermediary connecting services" (directories, lead generators, matching and bidding sites, Q&A sites and similar marketplaces) on three conditions: tell each client about the relationship and any fees you pay the platform, check that the platform meets eight requirements before and while you use it, and pull out if it won't fix a problem.
Pay-per-lead and a reasonable flat fee per hire are allowed. Fees tied to the case outcome or calculated as a percentage of your legal fees are not, except for bar association and legal aid referral services. The platform can't recommend you, though it can show reviews, ratings and search results the consumer filters.
When a firm asks us whether to keep paying a lead platform or move that money into ads it controls, this is the rule check we run for Illinois. This is a plain summary for marketing planning, not legal advice. Check the current rule with your bar or law society. We work with law firms across the US and Canada, and also in Australia and the UK.
What counts as an ICS
Almost any site that lists lawyers or passes a person's details to lawyers is an "intermediary connecting service".
Comment [6] to Rule 7.2 defines the term broadly, and comment [6A] lists the three things it doesn't cover.
| Type | Covered? | Examples in the rule's words |
|---|---|---|
| Marketplaces | Yes | A lawyer directory, referral service, matching service, bidding site, question-and-answer site, lead generator, or similar marketplace |
| Prepaid plans | Yes | A prepaid or group legal service plan or similar delivery service |
| Bar and legal aid referral services | Yes, with lighter rules | A bar association or legal aid organization lawyer referral service |
| Lawyer-to-lawyer referrals | No | Individual lawyer-to-lawyer referrals |
| Reciprocal referral deals | No | Reciprocal lawyer-to-lawyer or lawyer-to-nonlawyer professional referrals (covered by 7.2(b)(3)) |
| Court appointments | No | A tribunal, or an agency acting for one, appointing or assigning lawyers |
Paying for ordinary advertising is a separate permission. Rule 7.2(b)(1) and comment [5] allow paying for online directory listings, internet-based ads, sponsorships and group advertising, and paying marketing vendors and website designers. A Google search ad you run in your own account is advertising; a site that hands you a named person who asked for a lawyer is a connecting service.
Tell the client
Every client who came through a platform must be told about the relationship and what you pay it.
Rule 7.2(c) sets the timing: at the time of the connection or at the outset of the representation.
The disclosure has up to three parts: the relationship between you and the platform; if applicable, whether you pay it a connecting fee; and whether you pay a fee connected with comparative advertising, ratings, reviews or rankings on it. The last one catches paid placement and "featured lawyer" upgrades on directories.
Tag the source at intake
Every new lead gets a source field in the CRM. If the source is a platform, that tag is what triggers the disclosure.
Add a line to the engagement letter
A short paragraph naming the platform, the relationship, and whether you pay per connection or for placement. It's the simplest way to make the disclosure at the outset and keep proof of it.
Train whoever answers first
If the disclosure happens at connection, the intake script carries it. Our legal answering services guide covers what intake should say.
Check the platform
Before and while you use a platform, you take reasonable steps to confirm eight things.
Rule 7.2(c)(1) to (8) lists them. Paragraph (d) says a written certification from the platform covers six of them; the other two you check yourself.
| Condition | In plain words | Covered by the platform's written certification? |
|---|---|---|
| (1) No rule-breaking requests | It doesn't ask you to break the Illinois rules | No, check yourself |
| (2) No interference | It doesn't interfere with the client relationship or your judgment, including by setting your fee | No, check yourself |
| (3) No practicing law | It doesn't give legal advice or services | Yes |
| (4) Nothing false or misleading | About itself, you, your fees or services | Yes |
| (5) No improper solicitation | Its staff and agents don't solicit in ways Rule 7.3 bans | Yes |
| (6) No ownership by your firm | Neither you nor anyone in your firm owns, controls or manages it | Yes |
| (7) Public rating criteria | If it rates you, the criteria are public and it says whether you can dispute ratings | Yes |
| (8) Fee and recommendation limits | Outside bar and legal aid services: no outcome-based or percentage-of-fee charges, no recommending you, no holding client funds | Yes |
Comment [8A] spells out what interference looks like: a platform requiring you to work only with it, barring you from taking clients outside it, or restricting the public's access to you after you leave. It may require malpractice insurance as a condition of joining.
How you can pay
Pay per lead and a flat fee per hire are allowed; a share of your fee is not.
Comment [7] lists what "usual charges" may include, and paragraph (c)(8) draws the limits for platforms that aren't bar or legal aid services.
| Pricing model | Allowed? | Rule |
|---|---|---|
| Flat listing or subscription fee | Yes | Usual charges; advertising costs under 7.2(b)(1) |
| A set price per lead | Yes | Comment [7]: "paying the ICS for generating client leads" |
| A reasonable flat fee for each connection that becomes a client | Yes | Comment [7]: a "reasonable connecting fee for every connection that results in a potential client hiring the lawyer" |
| A fee that depends on the case outcome | No | 7.2(c)(8)(i) |
| A percentage of your anticipated or actual fees | No | 7.2(c)(8)(ii), except bar and legal aid services |
| The platform collecting the client's payment | Only if its processor passes it straight to you | 7.2(c)(8)(iv) |
The per-hire fee is the detail that surprises people. Illinois allows a flat amount per hire, which many states treat with suspicion, but the amount can't move with the size of the case or your fee. A platform quoting "10% of the fee" or "$500 if you win" is outside the rule.
When a platform breaks the rule
If you learn a platform isn't complying, you ask it to fix it, and you withdraw if it doesn't.
Paragraphs (e) and (f) set what happens after you've signed up.
- Correct or withdraw (7.2(e))
If you know the platform isn't meeting any of the eight conditions, withdraw or ask it to correct the problem. If it doesn't fix it within a reasonable time, you must withdraw. You don't have to drop matters it already sent you.
- Don't direct or ratify (7.2(f))
You may not direct, order or knowingly ratify anything the platform does that would break the Illinois rules. The written certification protects your due diligence; it doesn't cover conduct you know about.
- Recommending language (7.2(c)(8)(iii))
Watch the platform's marketing copy. It may show reviews, ratings and a list from the consumer's own search, but it may not say or imply it recommends or refers a lawyer. "We match you with the right lawyer" is the phrase to look for.
The rest of Illinois' ad rules
Outside lead platforms, Illinois' rules are short, with two firm requirements and a strict specialist rule.
There's no filing in Illinois. Rules 7.1 to 7.4 set what every communication needs.
- Name and office address (7.2(a)): every communication includes the name and office address of at least one lawyer or firm responsible for its content. No exception is written in for short formats.
- "Advertising Material" (7.3(c)): targeted written, recorded or electronic messages to someone known to need help in a matter carry the words on the envelope and at the beginning and end of the message.
- Protective order respondents (7.3(b)(3)): no soliciting the respondent before they've been served in an ex parte protective order case.
- Specialists (7.4): the Supreme Court of Illinois doesn't recognize specialty certifications. "Certified", "specialist" and "expert" may appear only when identifying a certificate or award, with a statement that the Court doesn't recognize certifications and the award isn't required to practice in Illinois.
- Results (7.1 comment [3]): truthful reports of results can mislead by creating an unjustified expectation.
Rule 7.3's comment [1] says websites, banner ads and responses automatically generated by internet searches aren't solicitation. The firm-wide picture by state is in our lawyer advertising rules hub, and the ABA baseline Illinois departs from is in our ABA Model Rules guide.
In our client work
We see firms come to us after lead platforms, and the 2025 rule makes the trade-off clearer.
When we take on a firm that buys leads, we review the platforms against Rule 7.2(c) and compare their cost per signed case with ads the firm owns.
Lead platforms aren't banned, and some work. The cost is that the firm doesn't own the source: the platform sets the price, may sell the same person to other firms, and now adds a disclosure and a yearly check. Ads run in the firm's own Google Ads or Local Services Ads account build something the firm keeps.
Say an Illinois personal injury firm pays a platform $300 per lead and buys 20 a month, $6,000, signing 3. That's $2,000 per signed case before any disclosure work. If the same $6,000 in its own ads signs 3 or more, it's at least even and the firm owns the account and the data. Our cost per signed case guide walks through that math.
Firms tell us this story often. One landlord-side real estate lawyer came to us in debt after burning thousands on bought leads, and has since had $30,000 to $50,000 months for over two years. Our guide to paying for leads and referrals compares the Illinois rule with other states.
Common mistakes
Where firms go wrong.
The Illinois platform mistakes we find when we review a firm's lead sources.
No disclosure to clients
Rule 7.2(c) requires telling each client about the platform relationship and fees, at connection or at the outset. Put it in the engagement letter.
No written certification on file
Paragraph (d) lets you rely on the platform's written confirmation for six conditions. Without one, you're doing all eight checks yourself.
Percentage or win-based pricing
Outside bar and legal aid services, outcome-based fees and fees calculated as a percentage of yours are banned under 7.2(c)(8).
Exclusive contracts
Comment [8A] treats requiring you to work only with one platform, or limiting clients you take outside it, as interference with your judgment.
"Specialist" in ads
Illinois recognizes no certifications. Unless you're naming a specific award with the required statement, leave the word out.
Real results
What this looked like for real firms.
Firms that came to us after bought leads and lead vendors didn't work out.
Identifying details are anonymized to protect our clients. Individual result, not a promise or prediction of any specific outcome for your firm.
FAQ
Questions lawyers ask us.
Straight answers to the questions that come up most.
What is an intermediary connecting service in Illinois?
Under comment [6] to Rule 7.2, it's a lawyer directory, referral service, matching service, bidding site, question-and-answer site, lead generator or similar marketplace, plus prepaid legal plans and bar or legal aid referral services. Lawyer-to-lawyer referrals, reciprocal referral deals and court appointments aren't included.
When did Illinois' new lead platform rule take effect?
The Illinois Supreme Court amended Rule 7.2 on April 1, 2025, effective July 1, 2025. It added paragraphs (c) to (f) and new comments on intermediary connecting services.
Can Illinois lawyers pay per lead?
Yes. Comment [7] says usual charges may include paying the platform for generating client leads, and a reasonable connecting fee for each connection that results in a hire, as long as the platform doesn't recommend you and the fee isn't outcome-based or a percentage of your fees.
What do I have to tell clients who came from a directory or lead site?
At the connection or the start of the representation: the relationship between you and the platform, whether you pay it a connecting fee, and whether you pay for comparative advertising, ratings, reviews or rankings on it. Our CRM basics guide covers source tracking that makes this routine.
Do Illinois lawyers file ads with anyone?
No. Illinois has no filing or pre-approval requirement. Every communication still needs the name and office address of a responsible lawyer or firm under Rule 7.2(a), and targeted solicitations need the "Advertising Material" label.
Does the Illinois rule apply to Google Local Services Ads?
No Illinois court or regulator page we read addresses Local Services Ads by name. Google charges per lead and shows ratings and reviews, so firms using it should read Rule 7.2(c) with their ethics counsel. How Google charges is in our LSA lead credits guide.
Can I call myself a specialist in Illinois?
Generally no. Rule 7.4 says the Supreme Court of Illinois doesn't recognize specialty certifications. "Certified", "specialist" or "expert" may appear only to identify a certificate or award, with the statement Rule 7.4(c)(2) requires.
Where we do this
The services this guide touches.
What this looks like when we run it for a firm, with a demo for your practice on each page.
Sources
Where these facts come from.
Official pages we read when writing this page. Platforms and rules change, so check the current version before you act on any of it. This is marketing guidance, not legal advice.
- Illinois Courts, Supreme Court Rules, Article VIII (Rules of Professional Conduct)
- Illinois Courts, Rule 7.2: Advertising (amended April 1, 2025, effective July 1, 2025)
- Illinois Courts, Rule 7.3: Solicitation of Clients
- Illinois Courts, Rule 7.4: Communication of Fields of Practice and Specialization
- Illinois Courts, Rule 7.1: Communications Concerning a Lawyer's Services
Written by
Founder of Ad Hoc Digital. Leads strategy and works directly with every client firm on AI search, Local Services Ads, Google Ads and Meta ads.
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