Consent and compliance

Iowa ban-the-box rules (2026): no state law, no city ordinances allowed, and the bill that stalled

On this page
  1. Does Iowa have a ban-the-box law?
  2. Can Iowa cities or counties adopt their own rules?
  3. What was Senate File 155?
  4. Which rules apply in Iowa?
  5. What will an Iowa record check show?
  6. What federal rules still apply in Iowa?
  7. What changes for jobs across the Iowa border?
  8. What should recruiters and staffing agencies do in Iowa?
  9. A script for Iowa screens
  10. An Iowa checklist for recruiting desks
  11. Questions people ask

Iowa has no statewide ban-the-box law as of October 2026: no statute limits when a private employer may ask about arrests or convictions, and the one bill that would have created a rule, Senate File 155 of 2025, stalled in a Senate subcommittee. Iowa cities and counties cannot step in, because Iowa Code 364.3(12) and 331.304(12) bar local rules on hiring practices that go beyond state or federal law. That leaves federal law, the state's rules on what a criminal record check shows, and the law of neighboring states such as Minnesota and Illinois for jobs located there.

Not legal advice. This page relies on Iowa Code 364.3 and 331.304 (Iowa Code 2026) and Senate File 155 of the 91st General Assembly as published on the Iowa Legislature's site, plus federal law, as of October 2026. We did not review state agency hiring policies. Ask Iowa employment counsel before relying on this.

Does Iowa have a ban-the-box law?

No. We found no Iowa statute that restricts when a private employer may ask about criminal history, and this site's Iowa background check laws and hiring employees in Iowa pages reach the same result. Under state law, an Iowa employer may ask on the application, in a screen or in an interview. We could not confirm a statewide rule for state agency applications either, and did not review agency hiring policies; if you recruit for a state agency, ask how its application handles criminal history.

Can Iowa cities or counties adopt their own rules?

No, and this is what makes Iowa different from most states without a statewide law. Under Iowa Code 364.3(12)(a), "a city shall not adopt, enforce, or otherwise administer an ordinance, motion, resolution, or amendment providing for any terms or conditions of employment that exceed or conflict with the requirements of federal or state law relating to a minimum or living wage rate, any form of employment leave, hiring practices, employment benefits, scheduling practices, or other terms or conditions of employment." Iowa Code 331.304(12)(a) says the same for counties.

"Hiring practices" is named outright, and a rule on when employers may ask about criminal history is a rule about hiring practices. Subsection (b) of each section adds that an ordinance adopted before March 30, 2017 that violates the rule "is void and unenforceable on and after March 30, 2017." So in Des Moines, Cedar Rapids, Davenport, Iowa City or Waterloo, a recruiter should not expect a local fair chance ordinance covering private employers, and any change for private employers would have to come from the Legislature.

What was Senate File 155?

Senate File 155, introduced by Senator Bisignano on January 29, 2025, would have created a new Iowa Code chapter on prohibited hiring practices. Its introduced text would have:

  • covered employers with four or more employees in the current or preceding year, their agents, and employment agencies, defined as anyone who regularly brings together those wanting to employ and those wanting work;
  • barred them from inquiring about or requiring disclosure of an applicant's criminal record "until the applicant's interview is being conducted or, if an interview will not be conducted, until after a conditional offer of employment";
  • exempted positions where federal or state law requires excluding applicants with certain convictions, and positions needing a fidelity or equivalent bond, but only if the employer used a separate application form naming the position, the law or bonding requirement and the disqualifying offenses; and
  • defined criminal record broadly, from arrests and charges through deferred judgments and convictions.

The Senate referred it to the Workforce Committee, which assigned a subcommittee on January 30, 2025. The Legislature's bill history shows no action after that, and the 91st General Assembly's 2026 session has adjourned, so the bill did not pass. It is still useful as a preview: its interview trigger and its coverage of employment agencies are what a future Iowa bill would likely ask of recruiters.

Which rules apply in Iowa?

ItemThe ruleSource
Private employersNo timing rule for criminal history questionsNo statute found; SF 155 (2025) did not pass
City ordinancesMay not set hiring-practice rules beyond state or federal lawIowa Code 364.3(12)
County ordinancesSame limitIowa Code 331.304(12)
Pre-2017 local rulesVoid and unenforceable from March 30, 2017 if they violate the limit364.3(12)(b), 331.304(12)(b)
State agency applicationsNo statewide rule confirmedNot confirmed; ask the agency
Federal contractorsNo criminal history request before a conditional offer for contract-related roles, with exceptions41 U.S.C. 4714
Screening company reportsDisclosure, authorization and adverse action stepsFCRA; see our FCRA guide

What will an Iowa record check show?

The rules that matter in Iowa are about the record, not the question. A check through the Iowa Division of Criminal Investigation shows different things with and without the candidate's signed release, and expunged cases and completed deferred judgments are handled differently from ordinary convictions. Our Iowa background check laws page sets out those rules with the Iowa Code sections. For recruiters, the practical point is that a "no" to a conviction question can be truthful even when a deferred judgment or an expunged case turns up in another source, so the client's question should say which records need not be disclosed.

What federal rules still apply in Iowa?

Title VII still governs how records are used. The EEOC rescinded its 2012 guidance on arrest and conviction records on October 28, 2026, effective immediately, and its announcement says Title VII "continues to prohibit discrimination based on race or national origin." The disparate impact provision, 42 U.S.C. 2000e-2(k), is unchanged, and courts decide those claims. Iowa is in the Eighth Circuit, whose 1975 decision in Green v. Missouri Pacific Railroad Co. weighed the nature and gravity of the offense, the time since it and the nature of the job. Using those Green factors remains a sound way to make and document a decision. Federal contractors may not request criminal history from applicants for contract-related positions before a conditional offer under 41 U.S.C. 4714, unless a law requires it or the work involves classified information or sensitive law enforcement or national security duties.

What changes for jobs across the Iowa border?

Iowa borders states with very different rules. Ban-the-box laws generally attach to where the job is, and each sets its own coverage test. Minnesota and Illinois regulate private employers; see Minnesota's ban-the-box law and Illinois's ban-the-box law. Nebraska's statute covers public employers only, and Missouri's rule for private employers is a Kansas City ordinance; see Nebraska and Missouri. A Quad Cities or Omaha-Council Bluffs desk should record the work location on every requisition.

What should recruiters and staffing agencies do in Iowa?

With no state or local rule, a consistent practice is the protection. Most agencies keep criminal history out of screens and submittals and let the client handle it at the background stage, after an interview or offer. That also matches the approach SF 155 proposed, so a desk that works this way would need little change if a future bill passes. Settle at intake:

  • Where will the person work: Iowa, Illinois, Minnesota, Nebraska or Missouri?
  • Is the role related to a federal contract?
  • Does a law disqualify people with certain convictions from the job, or require a bond or check? Which one?
  • Does the client's question tell applicants which expunged or deferred records need not be disclosed?
  • Who requests the DCI record or orders a screening report, and who sends the FCRA notices? Is your agency set up in Iowa? See Iowa staffing agency licensing.

A script for Iowa screens

Candidate volunteers a conviction: "Thanks for telling me. It isn't part of my screen and I won't note it. If the employer runs a background check, that happens later."

Client asks whether a city rule applies: "Iowa law doesn't let cities set their own hiring rules on this, so there's no local ordinance to follow. Federal rules still apply to how a record is used."

Client with an Illinois opening asks you to ask: "This job is in Illinois, and Illinois limits when employers can ask. Let's leave it to the stage that law allows."

An Iowa checklist for recruiting desks

  1. Record the work location and apply the neighboring state's law for out-of-state roles.
  2. Apply the conditional offer rule to federal contract roles.
  3. Keep criminal history out of screens as a consistent practice.
  4. Keep volunteered details out of notes. See what not to write in interview notes.
  5. For the national picture and scripts for stricter states, see ban-the-box laws and interview questions.

Questions people ask

Does Iowa have a ban-the-box law?

No. As of October 2026, Iowa has no statewide law limiting when a private employer may ask about criminal history. Senate File 155 of 2025 would have barred employers with four or more employees and employment agencies from asking before the interview, but it never moved past a Senate subcommittee.

Can an Iowa city pass its own ban-the-box ordinance?

No. Iowa Code 364.3(12) bars cities, and 331.304(12) bars counties, from adopting, enforcing or administering any ordinance on terms or conditions of employment that exceed or conflict with state or federal law on hiring practices, wages, leave, benefits or scheduling. Local ordinances adopted before March 30, 2017 that violate the rule are void.

What would Iowa's proposed ban-the-box bill have required?

SF 155, introduced by Senator Bisignano in January 2025, would have barred employers with four or more employees and employment agencies from asking about criminal records until the interview, or until a conditional offer if there is no interview, with exceptions for jobs where law requires excluding certain convictions or a fidelity bond is needed. It was assigned to a subcommittee on January 30, 2025 and went no further.

Which federal rules apply to criminal history questions in Iowa?

Title VII governs how records are used, even after the EEOC rescinded its 2012 arrest and conviction guidance on October 28, 2026. The FCRA governs reports from screening companies, and 41 U.S.C. 4714 bars federal contractors from requesting criminal history before a conditional offer for contract-related positions, with exceptions.