OMA section 2.06(a)

OMA

5 ILCS 120/2.06(a). Section 2.06 overview: Every body must keep written minutes of all meetings (open and closed) and a verbatim audio/video recording of closed sessions specifically. Open-meeting minutes must be approved within 30 days (or by the second subsequent regular meeting) and made public within 10 days after approval. This is the section that governs when closed-session minutes/recordings eventually have to be released too.

23 issues across 22 determination letters:16 violation found · 6 no violation · 1 no determination / resolved.

Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.

Authorities the Bureau cites most on this issue

Ill. Att'y Gen. PAC Req. Rev. Ltr. 26700 cited 2 times
Ill. Att'y Gen. PAC Req. Rev. Ltr. 40309 cited 2 times
Gosnell v. Hogan, 179 Ill. App. 3d 161, 170 (1989) cited 1 times
County board minutes of closed-session motions (PAC Req. Rev. Ltr. 61021) cited 1 times
Closed-session discussion of police service consolidation (PAC Req. Rev. Ltr. 51987) cited 1 times

How to challenge a denial on this issue

AI-generated summary of the decisions listed on this page, with each point linked to the letters it comes from. Determination letters are not binding precedent and this is not legal advice. Open the letter and check the PDF before relying on any point.

When a challenge is strong

The meeting minutes identify only topics but do not summarize the main points of discussion. Section 2.06(a) requires a summary of discussion on all matters proposed, deliberated, or decided; merely listing topics is insufficient.Based on: 2025 · A board's meeting minutes and vot… · 2018 · Agenda notice and approval of mee… · 2018 · Closed-session minutes for a scho…
+3 more
2018 · Closed-session discussion of poli… · 2020 · A school board's agenda descripti… · 2019 · Procedures for approving and publ…
The public body failed to keep any written minutes for a meeting (open or closed), including subcommittee or gathering meetings. Public bodies must keep written minutes of all meetings, with no exception for subcommittees or informal gatherings that constitute meetings under OMA.Based on: 2024 · A DEI subcommittee's failure to p… · 2020 · City council conference call gath… · 2018 · Maintenance and storage of open s…
+5 more
2018 · Unannounced pre-meeting gathering… · 2017 · A gathering of three aldermen abo… · 2017 · An advisory committee's special m… · 2022 · Closed-session minutes and remote… · 2011 · A committee's private discussion …
The public body did not create or preserve a verbatim audio or video recording of a closed session. The Act explicitly requires a verbatim recording of all closed meetings; failure to do so violates 2.06(a).Based on: 2023 · A school board's closed-session d… · 2019 · A committee's closed-session meet… · 2022 · Closed-session minutes and remote…
+1 more
2011 · A committee's private discussion …

When the public body usually wins

The challenge is based on de minimis inconsistencies (e.g., who made a motion, exact time of entering closed session) that do not deprive the public of meaningful information. The Bureau treats minor inaccuracies as insufficient to establish a violation where the public still receives a meaningful summary.Based on: 2024 · A village council's review of clo… · 2019 · County board minutes of closed-se…
The minutes lack a detailed description of an ordinance but no substantive discussion occurred on the matter. Minutes need only summarize discussion; if there is no discussion beyond identifying the ordinance, no further summary is required.Based on: 2019 · Meeting minutes describing an app…
The requester alleges a closed session recording is incomplete, but the public body produces a recording and evidence of no prior unrecorded deliberations, or evidence is conflicting. Absent evidence of missing portions, the Bureau will find compliance with the recording requirement.Based on: 2018 · A board member ordering a technic… · 2018 · Agenda items added to a special m…
The public body actually kept written minutes and the requester fails to show they were not kept. When the body demonstrates it kept minutes, a bare allegation of failure to keep them will not succeed.Based on: 2018 · Maintenance and storage of open s…

Points to put in your letter

Ask to inspect the meeting minutes. If they only list topics without summarizing the discussion, object that section 2.06(a) requires a summary of all matters proposed, deliberated, or decided.Based on: 2025 · A board's meeting minutes and vot… · 2018 · Agenda notice and approval of mee…
If the meeting was closed, request the verbatim recording. The Act requires a verbatim audio or video recording of all closed meetings.Based on: 2023 · A school board's closed-session d… · 2019 · A committee's closed-session meet…
Point out that vague entries like 'discussion of litigation' do not satisfy the summary requirement; the minutes must convey the main points of the discussion.Based on: 2018 · Closed-session minutes for a scho… · 2018 · Closed-session discussion of poli…
If minutes are entirely missing for a meeting or gathering, state that all public bodies must keep written minutes of every meeting, and the failure creates a violation.Based on: 2024 · A DEI subcommittee's failure to p… · 2017 · A gathering of three aldermen abo…

Common mistakes

Filing a challenge over minor, immaterial inaccuracies (like who seconded a motion) that do not affect the public's understanding of the meeting.Based on: 2024 · A village council's review of clo… · 2019 · County board minutes of closed-se…
Insisting that minutes include the full text of an ordinance or attached document rather than a summary of discussion; minutes need only summarize matters proposed, deliberated, or decided.Based on: 2019 · Meeting minutes describing an app…
A records coordinator assuming that subcommittees or informal gatherings of a quorum do not need written minutes.Based on: 2024 · A DEI subcommittee's failure to p…
A records coordinator believing that closed session minutes are adequate if they contain one-sentence general descriptions rather than a true summary of discussion.Based on: 2018 · Closed-session discussion of poli… · 2018 · Closed-session minutes for a scho…

Facts to gather first

Date and type of meeting (regular, special, committee, subcommittee, closed session).
Whether you have searched for or requested minutes and received only an agenda or topic list, or nothing.
A description of any discussion you recall that is not captured in the minutes.
For a closed session, whether you requested the verbatim recording and what the body provided in response.

These non-binding determination letters apply only to specific facts; always review the full PDF and consider that similar facts might lead to a different outcome.

Drafting brief for an AI assistant

Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: oma-2-06-a.json.

TOPIC: 5 ILCS 120/2.06(a)
SOURCE: Illinois Attorney General Public Access Bureau decisions compiled at https://illinoisfoia.org/issues/oma-2-06-a/
NOTE: Determination letters are not binding precedent; they show how the Bureau applies the law. Verify every decision against the source PDF before citing it.

VIOLATION FOUND (16):
- Insufficient summary of discussion in meeting minutes
  Rule: Minutes must include a summary of discussion on all matters proposed, deliberated, or decided, not merely identify topics; the Board's minutes lacked the main points of discussions.
  Decision: A board's meeting minutes and vote documentation (non-binding determination letter, December 12, 2025) https://illinoisfoia.org/opinions/letter-87758/
- Whether subcommittees must keep written minutes
  Rule: Public bodies must keep written minutes of meetings; subcommittees failed to do so.
  Decision: A DEI subcommittee's failure to provide meeting notice (non-binding determination letter, April 9, 2024) https://illinoisfoia.org/opinions/letter-78082/
- Failure to keep verbatim recording of closed session
  Rule: Public bodies must keep a verbatim audio or video recording of all closed meetings; failure to do so violates the Act.
  Decision: A school board's closed-session discussion of a book removal policy (non-binding determination letter, March 24, 2023) https://illinoisfoia.org/opinions/letter-71523/
- Failure to keep closed session minutes
  Rule: Public bodies must keep written minutes and verbatim recordings of all closed meetings, with no exception for closed sessions involving interviews.
  Decision: Closed-session minutes and remote meeting notice (non-binding determination letter, March 16, 2022) https://illinoisfoia.org/opinions/letter-69228/
- Failure to keep minutes
  Rule: Public bodies must keep minutes of meetings.
  Decision: City council conference call gatherings without public notice (non-binding determination letter, September 11, 2020) https://illinoisfoia.org/opinions/letter-62981/
- Meeting minutes lacked summary of discussion
  Rule: Meeting minutes must include a summary of discussion on all matters proposed, deliberated, or decided, and a record of any votes taken.
  Decision: A school board's agenda descriptions and meeting minutes (non-binding determination letter, May 29, 2020) https://illinoisfoia.org/opinions/letter-59235/
- Committees failed to keep proper meeting minutes
  Rule: Public bodies must keep written minutes containing a summary of discussion on all matters proposed, deliberated, or decided, and a record of votes taken.
  Decision: Procedures for approving and publishing committee meeting minutes (non-binding determination letter, September 17, 2019) https://illinoisfoia.org/opinions/letter-57900/
- Failure to create verbatim recording of closed session
  Rule: Public bodies must keep a verbatim audio or video recording of all closed meetings.
  Decision: A committee's closed-session meeting at an undisclosed location without a recording (non-binding determination letter, March 7, 2019) https://illinoisfoia.org/opinions/letter-55379/
- Insufficient closed session minutes
  Rule: Closed session minutes contained only vague, general sentences that did not summarize all matters proposed, deliberated, or decided as required by section 2.06(a).
  Decision: Closed-session discussion of police service consolidation (non-binding determination letter, April 18, 2018) https://illinoisfoia.org/opinions/letter-51987/
- Failure to keep adequate written minutes of closed session
  Rule: Minutes must include a summary of all matters proposed, deliberated, or decided; merely identifying topics is insufficient.
  Decision: Closed-session minutes for a school building bid (non-binding determination letter, February 15, 2018) https://illinoisfoia.org/opinions/letter-50632/
- Failure to keep minutes of August 9, 2017 Executive Board meeting
  Rule: Public bodies must keep written minutes of all meetings, whether open or closed.
  Decision: Maintenance and storage of open session minutes and closed session recordings (non-binding determination letter, March 28, 2018) https://illinoisfoia.org/opinions/letter-50424/
- Content of meeting minutes
  Rule: Minutes must include a summary of discussion on all matters proposed, deliberated, or decided, and a record of any votes taken; one-sentence general statements are insufficient.
  Decision: Agenda notice and approval of meeting minutes (non-binding determination letter, April 17, 2018) https://illinoisfoia.org/opinions/letter-50418/
- Failure to keep minutes of 6:30 p.m. gatherings
  Rule: Public bodies must keep written minutes of all meetings subject to OMA.
  Decision: Unannounced pre-meeting gatherings and a blocked board meeting (non-binding determination letter, February 20, 2018) https://illinoisfoia.org/opinions/letter-49828/
- Failure to keep minutes
  Rule: A public body must keep minutes of its meetings.
  Decision: An advisory committee's special meeting notice and agenda (non-binding determination letter, April 7, 2017) https://illinoisfoia.org/opinions/letter-44652/
- Gathering of City Council members without written minutes
  Rule: All public bodies must keep written minutes of all their meetings, including gatherings that constitute meetings under OMA.
  Decision: A gathering of three aldermen about city business (non-binding determination letter, July 5, 2017) https://illinoisfoia.org/opinions/letter-41800/
- Failure to keep minutes or recording of private gathering
  Rule: Public bodies must keep written minutes of all meetings, whether open or closed, and a verbatim record of closed meetings.
  Decision: A committee's private discussion of a redistricting map (non-binding determination letter, August 12, 2011) https://illinoisfoia.org/opinions/letter-14722/

NO VIOLATION (6):
- Accuracy of meeting minutes regarding motion maker
  Rule: De minimis inconsistencies in minutes concerning who made motions to enter closed session do not deprive the public of meaningful information.
  Decision: A village council's review of closed-session minutes (non-binding determination letter, March 5, 2024) https://illinoisfoia.org/opinions/letter-80205/
- Inconsistent open and closed session minutes
  Rule: De minimis inconsistencies in minutes about the precise time of entering closed session and who made motions do not violate OMA or deprive the public of meaningful information.
  Decision: County board minutes of closed-session motions (non-binding determination letter, December 19, 2019) https://illinoisfoia.org/opinions/letter-61021/
- Sufficiency of meeting minutes describing ordinance changes
  Rule: Minutes need only summarize discussion on matters proposed, deliberated, or decided; they need not recite the contents of an ordinance, and no substantive discussion occurred.
  Decision: Meeting minutes describing an approved ordinance (non-binding determination letter, February 1, 2019) https://illinoisfoia.org/opinions/letter-54370/
- Failure to record complete closed session
  Rule: Conflicting evidence and recording showing no prior unrecorded deliberations do not establish that the Board failed to record the complete closed session.
  Decision: A board member ordering a technician to stop recording a closed session (non-binding determination letter, May 9, 2018) https://illinoisfoia.org/opinions/letter-50757/
- Adequacy of closed session verbatim recordings
  Rule: A public body must keep verbatim recordings of closed meetings; absent evidence of missing portions, the body complies with the recording requirement.
  Decision: Agenda items added to a special meeting (non-binding determination letter, April 25, 2018) https://illinoisfoia.org/opinions/letter-50648/
- Failure to keep minutes of July 12, 2017 meeting
  Rule: Public bodies must keep written minutes of all meetings, whether open or closed.
  Decision: Maintenance and storage of open session minutes and closed session recordings (non-binding determination letter, March 28, 2018) https://illinoisfoia.org/opinions/letter-50424/

NO DETERMINATION / RESOLVED (1):
- Sufficiency of May 30, 2017 meeting minutes
  Rule: Minutes must include a summary of discussion on all matters proposed, deliberated, or decided, and a record of any minutes taken.
  Decision: A committee meeting with a quorum of the village board (non-binding determination letter, December 6, 2019) https://illinoisfoia.org/opinions/letter-48812/

MOST-CITED AUTHORITIES: Ill. Att'y Gen. PAC Req. Rev. Ltr. 26700; Ill. Att'y Gen. PAC Req. Rev. Ltr. 40309; Gosnell v. Hogan, 179 Ill. App. 3d 161, 170 (1989); Ill. Att'y Gen. PAC Req. Rev. Ltr. 61021; Ill. Att'y Gen. PAC Req. Rev. Ltr. 51987

TASK FOR THE ASSISTANT: Using only the decisions above, help draft a letter. Argue from the rule and cite the decision by name and date. Do not invent decisions.

Violation found (16)

Insufficient summary of discussion in meeting minutes
Rule: Minutes must include a summary of discussion on all matters proposed, deliberated, or decided, not merely identify topics; the Board's minutes lacked the main points of discussions.
Violation found A board's meeting minutes and vote documentation · December 12, 2025
Whether subcommittees must keep written minutes
Rule: Public bodies must keep written minutes of meetings; subcommittees failed to do so.
Violation found A DEI subcommittee's failure to provide meeting notice · April 9, 2024
Failure to keep verbatim recording of closed session
Rule: Public bodies must keep a verbatim audio or video recording of all closed meetings; failure to do so violates the Act.
Violation found A school board's closed-session discussion of a book removal policy · March 24, 2023
Failure to keep closed session minutes
Rule: Public bodies must keep written minutes and verbatim recordings of all closed meetings, with no exception for closed sessions involving interviews.
Violation found Closed-session minutes and remote meeting notice · March 16, 2022
Failure to keep minutes
Rule: Public bodies must keep minutes of meetings.
Violation found City council conference call gatherings without public notice · September 11, 2020
Meeting minutes lacked summary of discussion
Rule: Meeting minutes must include a summary of discussion on all matters proposed, deliberated, or decided, and a record of any votes taken.
Violation found A school board's agenda descriptions and meeting minutes · May 29, 2020
Committees failed to keep proper meeting minutes
Rule: Public bodies must keep written minutes containing a summary of discussion on all matters proposed, deliberated, or decided, and a record of votes taken.
Violation found Procedures for approving and publishing committee meeting minutes · September 17, 2019
Failure to create verbatim recording of closed session
Rule: Public bodies must keep a verbatim audio or video recording of all closed meetings.
Violation found A committee's closed-session meeting at an undisclosed location without a recording · March 7, 2019
Insufficient closed session minutes
Rule: Closed session minutes contained only vague, general sentences that did not summarize all matters proposed, deliberated, or decided as required by section 2.06(a).
Violation found Closed-session discussion of police service consolidation · April 18, 2018
Failure to keep adequate written minutes of closed session
Rule: Minutes must include a summary of all matters proposed, deliberated, or decided; merely identifying topics is insufficient.
Violation found Closed-session minutes for a school building bid · February 15, 2018
Failure to keep minutes of August 9, 2017 Executive Board meeting
Rule: Public bodies must keep written minutes of all meetings, whether open or closed.
Violation found Maintenance and storage of open session minutes and closed session recordings · March 28, 2018
Content of meeting minutes
Rule: Minutes must include a summary of discussion on all matters proposed, deliberated, or decided, and a record of any votes taken; one-sentence general statements are insufficient.
Violation found Agenda notice and approval of meeting minutes · April 17, 2018
Failure to keep minutes of 6:30 p.m. gatherings
Rule: Public bodies must keep written minutes of all meetings subject to OMA.
Violation found Unannounced pre-meeting gatherings and a blocked board meeting · February 20, 2018
Failure to keep minutes
Rule: A public body must keep minutes of its meetings.
Violation found An advisory committee's special meeting notice and agenda · April 7, 2017
Gathering of City Council members without written minutes
Rule: All public bodies must keep written minutes of all their meetings, including gatherings that constitute meetings under OMA.
Violation found A gathering of three aldermen about city business · July 5, 2017
Failure to keep minutes or recording of private gathering
Rule: Public bodies must keep written minutes of all meetings, whether open or closed, and a verbatim record of closed meetings.
Violation found A committee's private discussion of a redistricting map · August 12, 2011

No violation (6)

Accuracy of meeting minutes regarding motion maker
Rule: De minimis inconsistencies in minutes concerning who made motions to enter closed session do not deprive the public of meaningful information.
No violation A village council's review of closed-session minutes · March 5, 2024
Inconsistent open and closed session minutes
Rule: De minimis inconsistencies in minutes about the precise time of entering closed session and who made motions do not violate OMA or deprive the public of meaningful information.
No violation County board minutes of closed-session motions · December 19, 2019
Sufficiency of meeting minutes describing ordinance changes
Rule: Minutes need only summarize discussion on matters proposed, deliberated, or decided; they need not recite the contents of an ordinance, and no substantive discussion occurred.
No violation Meeting minutes describing an approved ordinance · February 1, 2019
Failure to record complete closed session
Rule: Conflicting evidence and recording showing no prior unrecorded deliberations do not establish that the Board failed to record the complete closed session.
No violation A board member ordering a technician to stop recording a closed session · May 9, 2018
Adequacy of closed session verbatim recordings
Rule: A public body must keep verbatim recordings of closed meetings; absent evidence of missing portions, the body complies with the recording requirement.
No violation Agenda items added to a special meeting · April 25, 2018
Failure to keep minutes of July 12, 2017 meeting
Rule: Public bodies must keep written minutes of all meetings, whether open or closed.
No violation Maintenance and storage of open session minutes and closed session recordings · March 28, 2018

No determination / resolved (1)

Sufficiency of May 30, 2017 meeting minutes
Rule: Minutes must include a summary of discussion on all matters proposed, deliberated, or decided, and a record of any minutes taken.
No determination / resolved A committee meeting with a quorum of the village board · December 6, 2019