OMA section 2.06(b)
OMA5 ILCS 120/2.06(b). 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.
9 issues across 5 determination letters:4 violation found · 5 no violation.
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 Determination letters are not binding precedent.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
- A township board's failure to approve meeting minutes (PAC Req. Rev. Ltr. 46954) cited 1 times
- Meeting minutes approval and website posting (PAC Req. Rev. Ltr. 71408) 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 Determination letters are not binding precedent and this is not legal advice.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 public body did not approve minutes of an open meeting within 30 days or by the second subsequent regular meeting, whichever is later. The Bureau repeatedly found this violates Section 2.06(b) when minutes are approved late or not at all.Based on: 2018 · Agenda notice and approval of mee… · 2024 · Meeting minutes approval and webs… · 2019 · Procedures for approving and publ…
- The governing body has a website maintained by full-time staff but did not post regular meeting minutes within 10 days of approval, and the body blames part-time or elected staff for the failure. The Bureau held that delegation of the posting duty to part-time or elected staff does not excuse non-compliance.Based on: 2024 · Meeting minutes approval and webs…
When the public body usually wins
- The public body does not post meeting minutes on its website because the website is maintained by a third party or not maintained by full-time staff. The OMA posting requirement applies only when the website is maintained by the public body's full-time staff.Based on: 2025 · City council meeting minutes · 2024 · Meeting minutes approval and webs…
- The public body refuses to provide copies of minutes and instead tells the requester to file a FOIA request. OMA requires only that minutes be available for inspection; the right to copies is governed by FOIA, not OMA.Based on: 2025 · City council meeting minutes
- A committee or advisory body of a public body did not post its meeting minutes on the public body's website. Only the governing body—not committees or advisory bodies—must post meeting minutes online under Section 2.06(b).Based on: 2016 · Advisory committee meeting minute… · 2019 · Procedures for approving and publ…
Points to put in your letter
- State the exact date of the meeting and the date the minutes were approved. Show that the approval happened more than 30 days after the meeting or after the second subsequent regular meeting, whichever was later.Based on: 2018 · Agenda notice and approval of mee… · 2024 · Meeting minutes approval and webs… · 2019 · Procedures for approving and publ…
- If the public body has a website run by full-time staff, note that the governing body must post regular meeting minutes within 10 days of approval. Point out that shifting the task to part-time or elected staff does not meet this requirement.Based on: 2024 · Meeting minutes approval and webs…
Common mistakes
- Insisting that the Open Meetings Act entitles you to free copies of minutes, when the Bureau has clarified that OMA only requires inspection.Based on: 2025 · City council meeting minutes
- Demanding that a committee or advisory body post its meeting minutes on the website.Based on: 2016 · Advisory committee meeting minute… · 2019 · Procedures for approving and publ…
- Assuming that any website—even one maintained by an outside vendor—triggers the duty to post minutes.Based on: 2025 · City council meeting minutes
- A records coordinator believing that assigning minute posting to an elected official or part-time staff member removes the public body's obligation to post.Based on: 2024 · Meeting minutes approval and webs…
Facts to gather first
- Date the meeting took place and date the minutes were approved (or whether they remain unapproved).
- Whether the public body's website is maintained by full-time staff (ask the body or check public records).
- Whether the body that held the meeting is the governing body or a committee/advisory body.
- The date the approved minutes were actually posted on the website, if at all.
These non-binding decision letters reflect the Bureau's past views; outcomes depend on the specific facts, and you should verify the relevant PDF decisions directly.
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-b.json.
Violation found (4)
Timely approval of minutes by Council and Board
Rule: A public body must approve open meeting minutes within 30 days or at its second subsequent regular meeting, whichever is later.
Violation found Meeting minutes approval and website posting · April 12, 2024
Website posting of minutes by the Council
Rule: A public body with a website maintained by full-time staff must post regular meeting minutes within 10 days of approval; delegating to part-time or elected staff does not avoid the requirement.
Violation found Meeting minutes approval and website posting · April 12, 2024
Committees failed to approve minutes within required timeframe
Rule: A public body that holds a meeting must approve the minutes of that meeting within 30 days or at its second subsequent regular meeting, whichever is later.
Violation found Procedures for approving and publishing committee meeting minutes · September 17, 2019
Timeliness of approval of prior meeting minutes
Rule: A public body must approve open meeting minutes within 30 days after the meeting or at its second subsequent regular meeting, whichever is later.
Violation found Agenda notice and approval of meeting minutes · April 17, 2018
No violation (5)
Posting meeting minutes on website
Rule: OMA requires posting minutes online only if full-time staff maintain the website; third-party maintenance does not trigger the requirement.
No violation City council meeting minutes · July 14, 2025
Requiring FOIA request for copies of minutes
Rule: OMA requires minutes be available for inspection, not that copies be provided; FOIA governs copy requests.
No violation City council meeting minutes · July 14, 2025
Website posting of minutes by the Board
Rule: OMA's website posting requirement applies only if the public body has a website maintained by its full-time staff; the Township had no such website.
No violation Meeting minutes approval and website posting · April 12, 2024
Committees' meeting minutes not posted online
Rule: Only a public body that maintains a website and is the governing body must post regular meeting minutes online; committees are not the governing body.
No violation Procedures for approving and publishing committee meeting minutes · September 17, 2019
Advisory committee minutes not posted on website
Rule: Section 2.06(b) requires only the governing body to post its meeting minutes on the public body's website, not advisory committees.
No violation Advisory committee meeting minutes posted online · March 18, 2016