Short answer — PENDING BILL, NOT LIVE LAW: Illinois House Bill HB 3673 (the Climate Corporate Accountability Act, 104th General Assembly) remains stalled in the House Rules Committee after its March 21, 2025 re-referral under Rule 19(a). Because HB 3673 was never enacted, the drafted July 1, 2026 rulemaking deadline and January 1, 2027 reporting date printed in the introduced text carry zero legal effect.
Many national ESG compliance calendars still flag Illinois’ drafted January 1, 2027 date as active. This watch brief clears that confusion while identifying the two regimes that are enforceable in Illinois today: the NAIC TCFD Climate Risk Disclosure Survey for licensed insurers (>=$100M DWP) and municipal building benchmarking in Chicago (>=50,000 sq ft), alongside any Illinois-headquartered enterprise triggering California SB 253 through California revenue nexus.
- Enacted Status: NONE (Re-referred House Rules Rule 19(a) March 21, 2025).
- Bill Design (>$1B Entities): Modeled on CA SB 253 with Scope 1, Scope 2, and Scope 3 emissions (+180 days post Scope 1/2) plus third-party verification.
- Distinct Governance Design: Assigns corporate registry oversight to the Illinois Secretary of State (consulting the Attorney General) plus macro-analysis by the University of Illinois or a national laboratory.
- Unpassed Dates Mooted: Drafted July 1, 2026 rulemaking & Jan 1, 2027 filing text are unpassed bill language — no filing is owed in Springfield.
- Live Illinois Obligations Today: NAIC TCFD Survey (insurers >=$100M DWP) and Chicago Energy Benchmarking Ordinance (>=50,000 sq ft annual June 1).
Verify Illinois HB 3673 Legislative Status & Active Illinois Filings
Why Drafted January 1, 2027 Text in HB 3673 Keeps Tripping Automated Calendars
When Rep. Kimberly Du Buclet introduced HB 3673 in February 2025, the bill text hard-coded statutory rollout dates — Secretary of State rules by July 1, 2026 and first-year Scope 1/2 disclosures starting January 1, 2027 (with Scope 3 180 days thereafter). Regulatory scrapers frequently index those printed dates without checking subsequent legislative posture.
In the 104th Illinois General Assembly, however, HB 3673 hit Rule 19(a) re-referral on March 21, 2025 without clearing committee or chamber floor votes. Any future revival in Springfield would require amended statutory deadlines after passage.
- Distinct Institutional Home: Rather than naming an environmental agency like CARB (CA) or NYSDEC (NY), HB 3673 places the public disclosure platform under the Secretary of State’s corporate division.
- Research Partner Mandate: Directs an academic institution such as the University of Illinois or a national laboratory to publish aggregate trend analysis from corporate disclosures.
| Measure / Mandate | Applies To | Legal Status (Nov 14, 2026) | Calendar Reality |
|---|---|---|---|
| IL HB 3673 (104th GA) | Entities >$1B doing business in IL | PENDING (House Rules Rule 19(a) Mar 2025) | Printed Jul 2026 / Jan 2027 dates NOT live law |
| NAIC Climate Risk Survey | IL-licensed insurers >=$100M countrywide DWP | LIVE Sectoral Mandate | Annual TCFD disclosure via CDI / IL DOI portal |
| Chicago Benchmarking | Covered Chicago buildings >=50,000 sq ft | LIVE Municipal Mandate | Annual June 1 Portfolio Manager + 3-yr data verif. |
What Companies Operating in Illinois Actually Owe Today
While Illinois corporations owe zero state-level corporate GHG filings under HB 3673, major Illinois firms frequently sit inside live climate reporting requirements via two adjacent channels: out-of-state nexus (>$757,070 California sales for >$1B entities under California SB 253) or sectoral/city mandates inside Illinois.
Illinois Department of Insurance partner carriers (>=$100M nationwide DWP) remain bound by the multi-state NAIC TCFD Climate Risk Disclosure Survey, and commercial/multifamily buildings >=50,000 sq ft in Chicago file annual energy disclosures every June 1.
Compliance Execution Checklist
| Step | Owner / Team | Auditable Deliverable |
|---|---|---|
| 1. Purge False Deadline | Legal / Risk | Correct any internal tracker showing 'IL Jan 1, 2027 Scope 1/2' — cite 104th GA Rule 19(a) status. |
| 2. Test CA Nexus | Tax / Sustainability | Verify if IL enterprise >$1B revenue crosses $757k CA sales (triggering live CA SB 253 instead). |
| 3. Separate City/Insurer Duties | CRE / Insurance | Confirm Chicago >=50k sq ft building benchmarking & IL NAIC >=$100M insurer filings separately. |
| 4. 105th GA Monitor | Gov Affairs | Watch post-election 2027 Illinois session introductions for successor Climate Corporate bills. |
Keep This Illinois Compliance Checklist Handy
Frequently Asked Questions
Do companies in Illinois have to report Scope 1 and Scope 2 emissions starting January 1, 2027 under HB 3673?
No. Although the introduced text of Illinois HB 3673 listed a January 1, 2027 start date, the bill was re-referred to the House Rules Committee under Rule 19(a) on March 21, 2025 and never enacted into law.
Who would administer Illinois HB 3673 if a future bill passes?
HB 3673 designated the Illinois Secretary of State (in consultation with the Illinois Attorney General) to adopt rules and contract for a public corporate emissions registry, paired with research analysis by the University of Illinois or a national laboratory.
Are there any live climate reporting laws in Illinois right now?
Yes, within specific sectors and cities: Illinois participates in the annual NAIC Climate Risk Disclosure Survey for insurers writing >= $100M countrywide DWP, and the City of Chicago enforces annual June 1 benchmarking for covered buildings >= 50,000 sq ft.
Primary Authorities & Official Resources
- Illinois General Assembly — 104th GA HB 3673 Official Bill Status
- BC ESG — California SB 253, SB 261 & AB 1305 Playbook
- BC ESG — NAIC TCFD Climate Risk Disclosure Survey Guide
Informational notice: This guide summarizes enacted statutes, regulations, or pending legislative records from the primary authorities linked above as of November 14, 2026. It is not legal, accounting, or licensed engineering advice.