INS-CLIMATE RISK DISCLOSURE
HB 3799 would require Illinois' large insurers to participate in NAIC climate-risk surveys, creating a Climate Risk Disclosure framework that triggers regulatory oversight.
HB 3799 would require Illinois' large insurers to participate in NAIC climate-risk surveys, creating a Climate Risk Disclosure framework that triggers regulatory oversight.
Status snapshot
- Introduced: 03/05/2025 (Rep. Bob Morgan). Passed the House 04/10/2025. Referred to the Senate (Arrived 04/14/2025). Multiple House and Senate floor and committee amendments were filed and considered through October–November 2025. As of 11/20/2025 additional Senate sponsorship was recorded. Several Senate amendments substantially rewrite parts of the bill; final enacted text may differ from the original House-introduced version.
Summary / Main intent
- The bill modifies insurer notice requirements for cancellations and nonrenewals and (in its House‑engrossed form) creates an Article establishing a Climate Risk Disclosure framework that would require large insurers to participate in climate-related surveys. Senate amendments (filed and adopted in October 2025 in varying forms) substantially alter the added Article to address rate standards and Department review authority for fire and extended coverage insurance filings. In short: the bill combines consumer‑notice protections, market‑conduct clarifications, and either climate‑disclosure obligations or new rate‑review authority depending on the version.
Key provisions (multiple versions noted)
Additional adjustments in Senate amendments clarify renewal‑notice timing and require companies to mail 60-day notices of renewal premium increases or deductible/coverage changes for whole lines of business in many circumstances.
Climate Risk Disclosure (House‑engrossed Article XLVIII)
Short title: “Climate Risk Disclosure Law.”
Applicability: Insurers licensed in Illinois under Classes 2 and 3 that write $100,000,000 or more in annual premiums (threshold may be changed by rule).
Requirement: Insurers subject to the Article must, upon direction from the Department of Insurance, participate in climate surveys issued by the National Association of Insurance Commissioners (NAIC). A House amendment removed language that would have explicitly required participation in Department‑issued climate surveys.
Market conduct and surveillance (amendments to Section 132 and related)
Definitions added/clarified for “market analysis,” “market conduct action,” “data call,” “desk examination,” and “market conduct surveillance personnel.”
Director’s market analysis tools and pre‑examination notice procedures are spelled out (e.g., pre‑examination conference at least 30 days’ notice).
Allows desk examinations, targeted or comprehensive on‑site exams, and coordination with other states.
Rate regulation (Senate Amendment substitute material)
New Article (in some Senate amendments) titled “Rates for Fire and Extended Coverage Insurance” with standards: rates must not be excessive, inadequate, or unfairly discriminatory; defines those terms.
Department authority to object to rate filings (notice requirements, independent actuarial testing, hearing procedures).
Senate Amendment 002 introduced a cap on renewal premium increases (no more than 10% for certain lines unless specified Department notice/compliance requirements are met).
Senate Amendment 003 added: (a) Department must send notice “within 60 days after receipt of a complete filing,” and (b) Department action objecting to a filing is subject to judicial review under the Administrative Review Law.
Who is affected
- Insurers licensed in Illinois (notably large property insurers under Classes 2 and 3 writing $100M+ in premiums under the House version).
- Policyholders of fire/extended coverage and other affected personal lines: changes to notice timing, reasons for nonrenewal/cancellation, and potential limits on renewal increases.
- Brokers, agents, mortgagees/lienholders (notification options).
- Illinois Department of Insurance (expanded survey direction authority, market‑conduct tools, rate‑review obligations and timing).
- NAIC (surveys and coordination) and potentially the courts (judicial review of Department rate objections).
Procedural/timeline notes
- The bill moved through House committees and floor quickly in spring 2025. It then proceeded to the Senate where multiple floor amendments were filed and adopted or considered in October 2025. Several Senate amendments substantially rewrote the new Article XLVIII, producing alternate policy directions (climate disclosure vs. rate regulation). Senate Amendment 003 added judicial‑review language and timing requirements for Department notices.
- Because the Senate adopted substitute language and multiple concurrence motions and Rules referrals occurred, readers should consult the latest enrolled/concurred version or the official bill text on the General Assembly site to determine the bill’s current operative language.
Compiled from official sources — confirm details with the bill’s official record.
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