Data is the Key – AIR Releases Study on Key Costs

Illinois Recovery Industry Addresses Key Creation Costs Following Data Privacy Law

Effective January 1, 2024, Illinois law requires all licensed recovery agencies to securely wipe personal data from vehicles repossessed within the state before releasing them. When a vehicle is recovered without a key, key creation becomes an essential part of legal compliance. The Illinois Commerce Commission does not permit exceptions based solely on the absence of a key.

Over the past two years, Illinois recovery agencies have invested significantly in locksmith training, advanced key-generation equipment, and contracted partners to meet these requirements efficiently while controlling costs.

Analysis

To evaluate concerns regarding key-related expenses, independent national research was conducted using forwarder-reported pricing and more than 24,500 agent-reported key transactions from 2025, including participation from nine members of the Alliance of Illinois Repossessors (AIR). The data shows that Illinois key pricing aligns with national averages and is not among the highest in the country, contrary to common assumptions. National agent-reported averages were approximately $266 for transponder keys and $374 for smart or proximity keys, reflecting the programming, security features, and equipment required for modern vehicles.

Recovery agencies do not benefit from the purchasing power or volume discounts available at the auction level and often operate in rural or geographically dispersed areas where locksmith availability is limited, leading to higher service or travel costs. Key pricing also varies by key type, including OEM, aftermarket, transponder, and smart or proximity keys, each requiring different levels of technology, labor, and security. Some cost comparisons rely on pre-2017 data, which does not reflect current compliance mandates, labor markets, or vehicle technology.

Compliance

Legal compliance requires repossessions to meet all statutory conditions to reduce risk and protect all parties. In Illinois, this includes secure data wiping, which often requires key creation. Attempts to bypass this obligation through hold-harmless language or alternative arrangements not recognized under Illinois law may create compliance gaps and increased exposure for both agencies and clients. A cooperative approach promotes lawful, efficient, and defensible recoveries while protecting consumer information.

Operational conditions within the industry have also evolved. Due to safety concerns and legal risks associated with debtor confrontations, many agencies nationwide have shifted recoveries to overnight hours, resulting in more vehicles being recovered without keys. In Illinois, however, the data privacy law has led to an increase in keys being obtained directly from debtors during personal property redemption, reducing the overall number of keys that must be created and, in many cases, saving financial institutions money.

Transparency and Benefits

While agent-level key costs may increase modestly, having a key delivers downstream benefits, including reduced claims exposure, lower transportation and storage costs, improved lot efficiency, enhanced vehicle intelligence, and faster disposition decisions by remarketing teams.

To promote transparency, AIR partnered with independent third-party Recovery Industry Professional Development (RIPD) to compile current, Illinois-specific key-pricing data from licensed recovery agencies. AIR believes this dataset represents the most accurate view of current market conditions and will make the information available to interested stakeholders.

The Illinois recovery community values its forwarder partnerships and recognizes their role in coordinating key creation. However, in some cases, additional markups may be applied without geographic or service-level differentiation, creating the appearance of higher agent costs despite underlying market consistency.

Our Commitment

AIR remains committed to transparency, compliance, and collaboration in support of a recovery environment that protects consumers, reduces risk, and delivers consistent results for clients.

Disclaimer: Invoiced key data is based on raw agent-level invoices reflecting actual services performed to meet legal compliance requirements. Recovery agencies are not involved in, nor aware of, any markups or additional service charges applied by forwarding partners. In contrast, auto auctions may, in some cases, absorb or offset costs such as key creation within other fee categories, which can make individual service costs appear lower or less visible. These differences in cost presentation can lead to misleading comparisons across the recovery and remarketing process.

About the Alliance of Illinois Repossessors (AIR)

AIR is a statewide association representing the interests of professional repossession agencies across Illinois. Dedicated to safety, compliance, and ethical practices, AIR advocates for higher industry standards and greater consumer protection.

Media Contact:

Alliance of Illinois Repossessors (AIR)

[email protected]

Data is the Key – AIR Releases Study on Key Costs – Data is the Key – AIR Releases Study on Key Costs – Data is the Key – AIR Releases Study on Key Costs

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