Company Bulletin 2026-08

Illinois Department of Insurance

JB PRITZKER ANN GILLESPIE Governor Director

TO: All Illinois Licensed Insurers

FROM: Ann Gillespie, Director

DATE: June 29, 2026

RE: Company Bulletin 2026-08 – Climate Risk Disclosure Survey

In cooperation with chief insurance regulators from American Samoa, California, Colorado, Connecticut, Delaware, District of Columbia, Guam, Hawaii, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Hampshire, New Jersey, New Mexico, New York, Northern Mariana Islands, Oregon, Pennsylvania, Puerto Rico, Rhode Island, US Virgin Islands, Vermont, Virginia, Washington, and Wisconsin, the Illinois Department of Insurance is conducting the Climate Risk Disclosure Survey for Reporting Year 2025.

For the current survey, Reporting Year 2025, all participating insurers are required to report using the Task Force on Climate related Financial Disclosure (TCFD)-aligned NAIC Climate Disclosure Risk Survey. For reporting year 2024, more than 1,800 companies responded to the Survey, capturing over 86% of the entire U.S. insurance market. For guidance on the specific survey sections and questions, reference the NAIC Climate Risk Disclosure Survey document. Pursuant to P.A. 104-0534, all insurance companies who are licensed in the State of Illinois and who collected direct written premium amounts of more than $100 million dollars nationwide during 2025 must respond to the survey.

The completed survey responses are due August 31, 2026. Please register and submit your survey responses to the Department by going to the survey registration on the interactive web application and following the registration and submission instructions. Insurance companies have to submit the TCFD- aligned Climate Risk Disclosure Survey through a PDF document. Companies can use the Survey Questions document attached to furnish their responses or upload their own TCFD-aligned report. All responses should be self-contained within a single document, rather than a link to a public report.

Companies within the same group whose policies and practices are the same and whose answers would not be materially different from each other may submit uniform group responses. When submitting group responses, please be certain to check the premium amounts for each individual company in the group that you are responsible for and submit a document for each company with more than $100 million in direct written premium nationwide.

In addition to the narrative Climate Risk Disclosure Survey, we invite companies to consider responding to the following voluntary closed-ended (Y/N) questions on this SurveyMonkey link. The voluntary closed-ended questions align with the NAIC Climate Risk Disclosure Survey.

Springfield Office Chicago Office 320 W. Washington Street 115 S. LaSalle St., 13th Floor Springfield, Illinois 62767 Chicago, Illinois 60603 (217) 782-4515 (312) 814-2420 Consistent with previous years, Climate Risk Disclosure Survey responses for the current and prior years are available to the public and can be found on the California Department of Insurance’s website. Additional information and guidance related to the survey can also be found on the California Department’s Climate Risk Disclosure website.

We have also provided a series of webinars on this Survey to build knowledge and capacity within the insurance sector and insurance companies. You can find the webinars archived at the Climate Risk and Resiliency Resource Center. We believe that these webinars will offer an excellent opportunity for participants to enhance their understanding of climate risk disclosure practices and gain practical knowledge on how to improve their own reporting.

Questions regarding this Company Bulletin should be directed to: DOI.InfoDesk@illinois.gov

Attachment: NAIC Climate Risk Disclosure Survey TCFD-Aligned Questions

Springfield Office Chicago Office 320 W. Washington Street 115 S. LaSalle St., 13th Floor Springfield, Illinois 62767 Chicago, Illinois 60603 (217) 782-4515 (312) 814-2420 NAIC CLIMATE RISK DISCLOSURE SURVEY TCFD-ALIGNED QUESTIONS UPDATED 2022 GOVERNANCE 1. Disclose the insurer’s governance around climate-related risks and opportunities. In disclosing the insurer’s governance around climate-related risks and opportunities insurers should consider including the following: • Identify and include any publicly stated goals on climate-related risks and opportunities. • Describe where climate-related disclosure is handled within the insurer’s structure, e.g., at a group level, entity level, or a combination. If handled at the group level, describe what activities are undertaken at the company level. A. Describe the board and/or committee responsible for the oversight of climate-related risks and opportunities. In describing the position on the board and/or committee responsible for the oversight of managing the climate-related financial risks, insurers should consider including the following: • Describe the position on the board and/or committee responsible for the oversight of managing the climate-related financial risks. B. Describe management's role in assessing and managing climate-related risks and opportunities.

STRATEGY 2. Disclose the actual and potential impacts of climate-related risks and opportunities on the insurer’s businesses, strategy, and financial planning where such information is material. In disclosing the actual and potential impacts of climate-related risks and opportunities on the insurer’s businesses, strategy and financial planning, insurers should consider including the following: • Describe the steps the insurer has taken to engage key constituencies on the topic of climate risk and resiliency. * • Describe the insurer's plan to assess, reduce, or mitigate its greenhouse gas emissions in its operations or organizations. * A. Describe the climate-related risks and opportunities the insurer has identified over the short, medium, and long term. In describing the climate-related risks and opportunities the insurer has identified over the short, medium, and longer term, insurers should consider including the following: • Define short, medium, and long-term, if different than 1-5 years as short term, 5-10 years as medium term, and 10-30 years as long term. B. Describe the impact of climate-related risks and opportunities on the insurer’s business, strategy, and financial planning. In describing the impact of climate-related risks and opportunities on the insurer’s business, strategy, and financial planning, insurers should consider including the following:

Springfield Office Chicago Office 320 W. Washington Street 115 S. LaSalle St., 13th Floor Springfield, Illinois 62767 Chicago, Illinois 60603 (217) 782-4515 (312) 814-2420 • Discuss if and how the insurer provides products or services to support the transition to a low carbon economy or helps customers adapt to climate-related risk. • Discuss if and how the insurer makes investments to support the transition to a low carbon economy. C. Describe the resilience of the insurer’s strategy, taking into consideration different climate-related scenarios, including a 2 degree Celsius or lower scenario.

RISK MANAGEMENT 3. Disclose how the insurer identifies, assesses, and manages climate-related risks. In disclosing how the insurer identifies, assesses, and manages climate-related risks, insurers should consider including the following: • Describe how the insurer considers the impact of climate related risks on its underwriting portfolio, and how the company is managing its underwriting exposure with respect to physical, transition and liability risk. * • Describe any steps the insurer has taken to encourage policyholders to manage their potential physical and transition climate related risks, if applicable. * • Describe how the insurer has considered the impact of climate-related risks on its investment portfolio, including what investment classes have been considered. * A. Describe the insurers’ processes for identifying and assessing climate-related risks. In describing the insurers’ processes for identifying and assessing climate-related risks, insurers should consider including the following: • Discuss whether the process includes an assessment of financial implications and how frequently the process is completed. * B. Describe the insurer’s processes for managing climate-related risks. C. Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the insurer’s overall risk management. In describing how processes for identifying, assessing, and managing climate-related risks are integrated into the insurer’s overall risk management, insurers should consider including the following: • Discuss whether climate-related risks are addressed through the insurer’s general enterprise-risk management process or a separate process and how frequently the process is completed. • Discuss the climate scenarios utilized by the insurer to analyze its underwriting risks, including which risk factors the scenarios consider, what types of scenarios are used, and what timeframes are considered. • Discuss the climate scenarios utilized by the insurer to analyze risks on its investments, including which risk factors are utilized, what types of scenarios are used, and what timeframes are considered.

METRICS AND TARGETS 4. Disclose the metrics and targets used to assess and manage relevant collateralized risks and opportunities where such information is material.

Springfield Office Chicago Office 320 W. Washington Street 115 S. LaSalle St., 13th Floor Springfield, Illinois 62767 Chicago, Illinois 60603 (217) 782-4515 (312) 814-2420 In disclosing the metrics and targets used to assess and manage relevant collateralized risks and opportunities where such information is material, insurers should consider including the following: • Discuss how the insurer uses catastrophe modeling to manage the climate-related risks to your business. Please specify for which climate-related risks the insurer uses catastrophe models to assess, if any. A. Disclose the metrics used by the insurer to assess climate-related risks and opportunities in line with its strategy and risk management process. In disclosing the metrics used by the insurer to assess climate-related risks and opportunities in line with its strategy and risk management process, insurers should consider including the following: • In describing the metrics used by the insurer to assess and monitor climate risks, consider the amount of exposure to business lines, sectors, and geographies vulnerable to climate- related physical risks [answer in absolute amounts and percentages if possible], alignment with climate scenarios, [1 in 100 years probable maximum loss, Climate VaR, carbon intensity], and the amount of financed or underwritten carbon emissions. B. Disclose Scope 1, Scope 2, and if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks. C. Describe the targets used by the insurer to manage climate-related risks and opportunities and performance against targets.

* Asterisks represent questions derived from the original Climate Risk Disclosure Survey.

Springfield Office Chicago Office 320 W. Washington Street 115 S. LaSalle St., 13th Floor Springfield, Illinois 62767 Chicago, Illinois 60603 (217) 782-4515 (312) 814-2420