Illinois Insurance Supplier Diversity Reporting Instructions Update
Summary
The Illinois Department of Insurance has issued updated instructions for annual insurance supplier diversity reports, effective for filings on or after April 1, 2026. These updated instructions replace previous guidance and clarify which entities are required to file and how to submit the reports.
What changed
The Illinois Department of Insurance has issued Company Bulletin 2026-03, providing updated filing instructions for annual insurance supplier diversity reports. This guidance supersedes CB 2024-09 and clarifies that risk-bearing entities, including insurance companies, HMOs, and accredited reinsurers with assets of at least $50,000,000, must file these reports annually on or after April 1, 2026. The bulletin specifies that the asset threshold is determined by the current year's Annual Statement total net admitted assets, and entities within the same holding company system may file on a group basis if independently subject to the requirement.
Affected entities must use the fillable PDF template available on the Department's website and file through SERFF using the specified TOIs and sub-TOIs. The reports must be marked as available for public access. Failure to comply with these reporting requirements could result in regulatory action. Compliance officers should ensure their organizations meet the asset threshold and are prepared to file the updated report by the April 1, 2026 deadline.
Source document (simplified)
Springfield Office 320 W. Washingto n Street Springfiel d, Illinois 62 767 (217) 7 82-4515 Chicago Office 115 S. LaSalle Street, 13 th Floor Chicago, Illi nois 60603 (312) 8 14-2420 Illinois Department of Insur anc e JB PRI TZK ER Governor ANN GILLESPIE Director TO: All Insurance Companies, Health Ma inte nance Organizations, Li mited Health Service Organizations, Dental Service Plan Co rporations, and Accredited Reinsu rers FRO M: Ann Gillespie, Director DAT E: February 6, 2026 R E: Company Bulletin 2026-03 In surance Supplier Diversity Re por ts (re pl ace s CB 20 24- 09) The pur po se of th is bu lle ti n i s to pr ovi de gui dan ce to r is k- bea rin g e nti ti es wit h updated filing instruct ions for submittin g the annual insurance supplier di versity reports required on or after April 1, 2026 pursuant to 215 ILCS 5/155.49. I. Which Entities Must F il e? The statute requires annual insurance supplier divers ity reports from “[e]very company authorized to do business in this State or accredited by this State with assets of at least $50,000,000…” 215 ILCS 5/155.49. This statute applies to: ins ur an ce companies; hea lt h ma in ten an ce organizations; li mit ed hea lth se rv ice organizations; dental service plan corporations; a n d accredited r ei ns ur ers. But, it does not apply t o: qualified group worker s com pens ation pools; domestic captive insurance co mp an ies; fraternal benefit societies; or any risk-bearing entity that, in this State, only transacts business to offer Medicare Part C or D plans. The statute applies regardless of where the authorized or ac credited entity is domiciled. The requirement to file a repo rt does not depend on the lines of business in which the risk-bearing entity transacts, unless in Illinois the entity transacts no business other than Medicare Part C or D plans. For determining whether a risk-bearing entity meet s the $50 million asset thre shold, use the Annual Statement’s total net admitted assets for the current year as reflected on the Assets page filed with the
Springfield Office 320 W. Washin gton Street Springfiel d, Illinois 62 767 (217) 7 82-4515 Chicago Office 115 S. LaSalle Street, 13 th Floor Chicago, Illi nois 60603 (312) 8 14-2420 Director for the year ending December 31st immediate ly preceding. For example, on the report to be filed by April 1, 2026, use the Annual Statem ent for the year e nding December 31, 2025. If more than one risk-be aring entity within the same insuranc e holding company system is independently subject to the statute, the risk-b earing entities may elect either to file separate reports o r to file a single report on a group basis. Multiple entiti es within the same insurance ho lding company system should not aggregate their assets for the purpose of determin ing whether they meet th e $50 million threshold. However, if one or more affiliated risk-bearing entities is independently subject to the filing requirement and they happen to pool assets or expenses in a joint procurement pr ogram, the report should reflect that pooling in the appropria te form field(s). II. How to Fi le Risk-bearing entities and reporti ng groups must use the fillable PDF template published on the Department’s Insurance Supplier Diversity webpage at https://idoi. illinois.gov/companies/industry- supplier-diversity. For the April 1, 2026 filing, an d any a nnual repor t ther eaf ter, the r epo rt template re mai ns published on the Department’s Insu rance Supplier Diversity webpage above. Risk-bearing entities and reporting groups mu st file their repor ts through SERFF (www.serff.com) and mark the reports availa ble for public access in accordance with 215 IL CS 5/155.49(b). The Department has created specific TOIs and sub-TOIs to be used for submitting these reports: Fo r all entities subjec t to report, use t he SERFF TOI: Annual Reports and sub-TOI: Supplier Diversity Report If an entity or reporting group tr ansacts both P&C and Life or H ealth-related lines of business, the filing need only be submitte d under one product line using the TOI/sub-TOI comb inations above. Please note that information in the reports should not be broken down by line of business. Information is only required to be reported at th e company or group-level. SERFF is be ing used because it is a widely familiar platform with a public access mechan ism, but unfortunately the platform can not be configured without TOI/sub-TOI. III. For mat ting Guidance Form fields will expand to accommodate as much text a s needed for entities and groups to respond to the prompts. For longer responses, it may be easier to draft in a diffe rent document and then copy/paste the response into the fi eld on the PDF template. Additional guid ance follows about certain questions. Question 3 Please separate all certifications with commas. If an explanation is needed about any certification, place the explanation in your response to question 6.
Springfield Office 320 W. Washin gton Street Springfiel d, Illinois 62 767 (217) 7 82-4515 Chicago Office 115 S. LaSalle Street, 13 th Floor Chicago, Illi nois 60603 (312) 8 14-2420 Question 4 For the portion of Question 4 with a breakdown of internal voluntary goals, please use the following format, separating each string with a carriage return: [Commodity Code / Descri ption of Procurement Category], [Type of Inclusion Supplier], [# / $ / % ] For the final element shown above as [#, $, %], provide only the type of quanti ty that your entity or group currently uses in voluntarily setting the internal goal. For ex ample, if you have a goal in a procurement category to spend $500,000 on inclusion suppliers or on a type of inclusion supplier, and if you do not express it as a percenta ge of your overall procurement budge t, just write the dollar amount. If the entity or group does not current ly break down its goals by specifi c types of inclusion suppliers, do not include the [Type of Incl usion Supplier] in the string. Any explanation of the strings should be added at th e end of the box after maki ng a carriage re turn after the last string. If additional explanation is needed about unique ci rcumstances, use the response field for question 6. Question 5 For the portion of question 5 about the results of the supplier divers ity program or other procurement program, please use the following format in each fi eld, separating each string with a carriage return: [Commodity Code / Description of Procurement Category], [Type of Inclusion Supplier], [# / $] If the entity or group has a supplier diversity progra m, in the section precede d by “For each type o f certified inclusion supplier the Entity / Group accepts or reco gnizes,” the entity or group should provide a breakdown of results by type of in clusion supplier even if internal goals are not currently broken down in that manner. For the final prompt asking for the percentage of total procurement sp end overall that is composed of total spend on inclusion suppliers overall, this figure should not be broken down by type of inclusion supplier. The answers are tota l perc entages that are calculated by: 1. Summing all the dollar amounts reported in th e “For each procurement category” section under the same column (IL or National) of sub-item ii. 2. Summing all the dollar amounts reported in th e “For each procurement category” section under the same column of sub-item i. 3. Dividing the sum for each column in Step 2 by the sum in the same column of Step 1. 4. Converting the decimal in Step 3 to percentage notation and writing in the IL or National box, as applicable. Question 6 Please use this field to explain a ny unique circumstances, irregularitie s, or qualifiers to any answers supplied elsewhere in the report.
Springfield Office 320 W. Washin gton Street Springfiel d, Illinois 62 767 (217) 7 82-4515 Chicago Office 115 S. LaSalle Street, 13 th Floor Chicago, Illi nois 60603 (312) 8 14-2420 IV. Relationship to Department Ru le s Entities and groups must follow the fo rm’s instructions identifying the in formation that must be reported. The form refers to the Department’s rule at 50 Ill. Adm. Code 910 for further guidance. Additional guidance has been posted on the Industry S upplier Diversity page of our we bsite in the form of FAQs. If a risk-bearing entity or reporting g roup has a question fo r the Department that is not addressed by the rule text, this bulletin, or th e FAQs, please contact the Department as directed at the e nd of this bulletin. Questions about this bulle tin may be directed to DOI.DataSecurity@Illinois.gov.
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