The Illinois Department of Insurance issued Company Bulletin 2026-03 on February 6, 2026. It replaces CB 2024-09 and resets filing instructions for annual insurance supplier diversity reports due on or after April 1, 2026 under 215 ILCS 5/155.49. We think the shift looks procedural, though compliance teams shouldn’t shrug it off.
The Department applies the mandate to every insurer authorized in Illinois or accredited by Illinois with at least $50 mn in assets.
Scope covers insurance companies, health maintenance organizations, limited health service organizations, dental service plan corporations, and accredited reinsurers.
Domicile doesn’t drive applicability. Lines of business don’t either, except for entities transacting only Medicare Part C or D in Illinois.
The bulletin carves out qualified group workers compensation pools, domestic captive insurers, fraternal benefit societies, and risk-bearing entities writing only Medicare Part C or D plans in the state.
According to Beinsure analysts, the Medicare-only limitation narrows exposure for certain niche carriers, though diversified groups remain in scope.
For the asset threshold, IDOI directs companies to rely on total net admitted assets reported in the Annual Statement for the current year.
Entities must reference the Assets page filed with the Director for the year ending December 31 immediately preceding the filing date.
For the April 1, 2026 submission, companies use figures as of December 31, 2025. It’s mechanical, but errors here trigger downstream issues.
Risk-bearing entities and reporting groups must complete the fillable PDF template posted on the Department’s Insurance Supplier Diversity webpage.
Filers submit through SERFF and designate the report for public access under 215 ILCS 5/155.49(b). The Department specifies SERFF TOI Annual Reports and sub-TOI Supplier Diversity Report.
Carriers writing both P&C and life or health business file under a single product line using the combined approach, without breaking data out by line.
Formatting rules tighten for Questions 3 through 6. The bulletin calls for comma-separated certifications.
It requires carriage-return-separated strings for goals and results, structured with commodity codes or procurement categories, inclusion-supplier type, and a #, $, or % where applicable.
According to our data, reporting teams trip over string formatting more than substance, and regulators won’t overlook sloppy inputs.
Entities within the same holding company system hold discretion to file separately or as a group. They cannot aggregate assets across affiliates to meet the $50 mn threshold.
Each entity stands on its own balance sheet for eligibility. Honestly, groups hovering near the line need to recheck numbers before assuming coverage.
