In a move signaling a deeper commitment to economic equity, Illinois regulators have refined the mechanism for tracking supplier diversity within the state’s powerful insurance sector, introducing updated procedures that demand careful attention from all covered entities. This guide breaks down the new requirements, offering a clear path to compliance for the annual reports due on or after April 1, 2026.
Understanding the New Mandate What Illinois Insurers Need to Know
The Illinois Department of Insurance (IDOI) has released Company Bulletin 2026-03, a document that formally replaces its predecessor, CB 2024-09, and establishes a new standard for annual supplier diversity reporting. This updated guidance applies to all required submissions filed on or after April 1, 2026, creating a revised framework designed to streamline data collection and enhance transparency. The bulletin outlines critical procedural changes impacting how insurers prepare, format, and submit their yearly data on spending with diverse-owned businesses.
At its core, the new mandate affects every Illinois-authorized insurance entity with significant assets, clarifying who must file, the specific template to be used, and the precise protocol for submission through the System for Electronic Rate and Form Filing (SERFF). This article serves as a comprehensive roadmap, guiding insurers through the updated process step-by-step. By understanding these adjustments—from determining filing obligations to mastering the new data formatting rules—companies can ensure their submissions are accurate, compliant, and contribute effectively to the state’s diversity objectives.
The Regulatory Context Why Supplier Diversity Reporting Matters
The foundation for this reporting requirement lies in Illinois state law, specifically 215 ILCS 5/155.49, which mandates that the insurance industry actively reports on its engagement with businesses owned by minorities, women, veterans, and individuals with disabilities. The state’s overarching goal is to leverage the significant procurement power of the insurance sector to create broader economic opportunities for these diverse communities. The annual reports are not merely a bureaucratic exercise; they are a vital tool for measuring progress and holding the industry accountable for its role in fostering an inclusive marketplace.
Company Bulletin 2026-03 should be viewed as a procedural refinement rather than a fundamental policy shift. The updated instructions are engineered to improve the quality and consistency of the data collected, allowing for more meaningful analysis and benchmarking across the industry. By standardizing the submission process and clarifying ambiguities, the IDOI aims to build a more robust and reliable dataset. Ultimately, this enhanced transparency helps policymakers, consumer advocates, and the industry itself to better understand where opportunities for diverse suppliers are growing and where more focused efforts are needed.
A Step-by-Step Guide to the Updated Filing Process
Step 1 Determining Your Filing Obligation
The $50 Million Asset Threshold
The primary determinant for whether an entity must file a supplier diversity report is its asset size. The requirement applies to any organization with total net admitted assets of at least $50 million. This figure is not arbitrary; it is a clear line established by regulators to focus the reporting mandate on insurers with a substantial economic footprint in the state.
To determine if this threshold is met, entities must refer to their Annual Statement for the year ending December 31 of the immediately preceding year. For example, for the report due on April 1, 2026, the controlling document is the Annual Statement filed with the Director for the year ending December 31, 2025. This backward-looking measurement ensures that the filing obligation is based on a finalized and officially reported financial position.
Identifying Covered and Exempt Entities
The scope of the filing requirement is broad and intentionally inclusive, capturing most risk-bearing entities authorized to conduct business in Illinois. This includes insurance companies, Health Maintenance Organizations (HMOs), Limited Health Service Organizations, dental service plan corporations, and accredited reinsurers. Notably, an entity’s domicile is not a factor; both domestic and foreign insurers are subject to the same rules if they meet the asset threshold and are authorized in the state.
However, the state has carved out specific exemptions for certain types of organizations. The list of excluded entities includes fraternal benefit societies, qualified group workers’ compensation pools, and domestic captive insurance companies. Additionally, any risk-bearing entity that exclusively transacts Medicare Part C or Part D plans in Illinois is exempt from this filing. Insurers should carefully review this list to confirm whether they fall into one of these specific carve-outs before beginning the reporting process.
Step 2 Preparing Your Report for Submission
Utilizing the Official IDOI Template
To ensure uniformity and streamline the review process, the IDOI mandates the use of a specific reporting template. All filers must download and complete the official fillable PDF form, which is available on the Department’s Insurance Supplier Diversity webpage. The use of this standardized document is not optional; submissions made in any other format will not be considered compliant.
This strict adherence to a single template is crucial for the integrity of the statewide diversity initiative. It allows the IDOI to aggregate data from hundreds of filers efficiently and accurately, creating a comprehensive picture of the industry’s procurement practices. By using the prescribed format, insurers contribute to a cleaner, more comparable dataset that supports the program’s transparency goals.
Deciding on an Individual vs. Group Filing
For entities that are part of a larger holding company system, the IDOI provides a degree of flexibility in how they submit their reports. These companies have the option to either file individually for each qualifying entity or to submit a single, consolidated report on a group basis. This choice allows corporate families to select the method that best aligns with their internal data management and reporting structures.
A critical rule governs group filings: the assets of the member companies are not aggregated to meet the $50 million threshold. Each entity included in a group report must independently satisfy the asset requirement. This provision prevents smaller, non-obligated affiliates from being inadvertently pulled into the reporting mandate simply by being part of a larger corporate structure. Therefore, holding companies must first assess each member’s assets individually before deciding on a consolidated filing strategy.
Step 3 Mastering the SERFF Submission Protocol
Correct SERFF Classification Is Crucial
All supplier diversity reports must be submitted electronically through the SERFF platform, and proper classification within the system is essential for a successful filing. The IDOI has provided exact filing codes that must be used: the Type of Insurance (TOI) must be designated as “Annual Reports,” and the sub-TOI must be specified as “Supplier Diversity Report.”
Using these precise codes ensures that the submission is routed correctly within the IDOI’s systems and processed without delay. Any deviation from this classification could lead to the report being misplaced, rejected, or flagged as non-compliant, potentially requiring the insurer to refile. Accuracy at this stage is a simple yet critical component of meeting the regulatory deadline and avoiding administrative complications.
A Note on Public Accessibility
A key aspect of the Illinois supplier diversity law is its emphasis on transparency. In alignment with this principle, 215 ILCS 5/155.49(b) requires that all submitted reports be made available to the public. To comply with this legal requirement, filers must mark their submission as available for public access within the SERFF system at the time of filing.
This is not a default setting and requires a deliberate action from the filer. Forgetting this step can render an otherwise perfect submission non-compliant. By making the reports public, the state ensures that stakeholders—including diverse supplier communities, policymakers, and the general public—can access the information and monitor the industry’s progress toward its diversity goals.
Simplifying for Multi-Line Insurers
Insurers that write multiple lines of business, such as both property and casualty and life or health-related products, are afforded a simplified submission process. Rather than preparing and filing separate reports for each line, these entities are instructed to submit a single, unified report. This consolidated filing should be submitted under just one of their product lines using the specified TOI and sub-TOI combination.
The data within this single report should not be broken down by line of business; instead, it should represent the entity’s total procurement activities. This approach streamlines the reporting burden for multi-line carriers and simplifies data analysis for the IDOI. It reflects a pragmatic understanding that an insurer’s supplier relationships are often managed at the corporate level rather than siloed within individual business segments.
Step 4 Adhering to Specific Data Formatting Rules
Formatting Guidelines for Key Questions
The IDOI has established specific formatting requirements for the data entered in Questions 3 through 6 of the official template to facilitate automated data processing. For questions related to certifications, filers must use a comma-separated list of values. This standardized input ensures that the various types of diverse supplier certifications can be parsed and categorized correctly by the Department’s systems.
For reporting on goals and results, a different format is required. Filers must use carriage-return-separated strings, with each line containing the relevant commodity code or procurement category, the type of inclusion supplier, and the corresponding metric. This metric should be presented as a number, dollar amount, or percentage, as applicable (e.g., #/$/%). Adhering to these precise formatting rules is vital for data integrity and prevents submissions from being rejected due to technical errors.
Key Takeaways A Quick Reference Summary
- New Guidance: Company Bulletin 2026-03 replaces CB 2024-09 for reports due on or after April 1, 2026.
- Who Must File: Illinois-authorized entities with $50M+ in prior-year assets.
- Filing Platform: Submissions must be made through SERFF using a specific template.
- Public Access: Reports must be marked as publicly accessible upon filing.
- Group Filings: Holding companies may file a consolidated report for their members.
Broader Implications and Future Outlook
The procedural updates outlined in Company Bulletin 2026-03 are part of a larger movement toward greater accountability in the corporate world, particularly concerning Environmental, Social, and Governance (ESG) and Diversity, Equity, and Inclusion (DEI) initiatives. As stakeholders increasingly demand transparency, regulators are responding with more sophisticated data collection mechanisms. The refined reporting process in Illinois allows for more accurate benchmarking, enabling a clearer view of which insurers are leading in supplier diversity and where systemic gaps remain.
This increased focus on quantifiable data suggests a future where supplier diversity programs are evaluated with the same rigor as other core business functions. As these programs mature, insurers might anticipate further regulatory adjustments aimed at capturing more granular data or tracking progress against industry-wide benchmarks. The current updates serve as a foundational step, building a more robust framework that can support more ambitious diversity and inclusion goals in the years to come. Insurers that proactively build strong data management practices will be best positioned to adapt to this evolving regulatory landscape.
Ensuring Compliance and Accessing Resources
Adherence to the new guidelines detailed in Company Bulletin 2026-03 was critical for a smooth and successful filing season. Insurers that took the time to thoroughly understand the updated requirements—from asset thresholds to specific SERFF protocols—were better equipped to avoid common pitfalls that can lead to rejected filings and potential compliance issues. The bulletin, in conjunction with existing regulations and FAQs, provided a complete toolkit for navigating the annual submission process.
To ensure continued compliance, companies reviewed the new bulletin in its entirety and consulted the IDOI’s Insurance Supplier Diversity webpage for the official template and supplementary materials, such as the FAQs and the full text of 50 Ill. Adm. Code 910. For any specific or unresolved questions, the IDOI designated a direct point of contact. By directing inquiries to DOI.DataSecurity@Illinois.gov, insurers obtained the necessary clarifications to ensure their reports were both accurate and fully compliant with state law.
