# Illinois Climate Corporate Accountability Act (HB 3673): Rule 19(a) Status & Live Compliance Check

> Canonical URL: https://bcesg.org/illinois-climate-corporate-accountability-act-hb-3673-watch/
> Jurisdiction: Illinois | Status: PENDING LEGISLATION — Re-referred to House Rules under Rule 19(a) (Not Enacted) | Reviewed: 2026-11-14

**Short answer — PENDING BILL, NOT LIVE LAW:** Illinois House Bill [HB 3673](https://www.ilga.gov/Legislation/BillStatus?DocNum=3673&GAID=18&DocTypeID=HB&SessionID=114) (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](https://bcesg.org/naic-climate-risk-disclosure-survey-tcfd-insurer-mandate-guide/) for licensed insurers (>=$100M DWP) and municipal building benchmarking in Chicago (>=50,000 sq ft), alongside any Illinois-headquartered enterprise triggering [California SB 253](https://bcesg.org/california-sb-253-sb-261-compliance-playbook/) through California revenue nexus.

### Statutory Status at a Glance
- **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).

## 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](https://bcesg.org/california-sb-253-sb-261-compliance-playbook/)) or NYSDEC ([NY](https://bcesg.org/new-york-climate-corporate-data-accountability-act-s9072a-a4282a-watch/)), 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. |

![Legislative status infographic for Illinois 104th General Assembly HB 3673 showing Rule 19(a) referral in House Rules, Secretary of State governance model, and live IL insurance/Chicago rules.](https://bcesg.org/wp-content/uploads/2026/11/infographic-il-hb3673.png)

## 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. |

## 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](https://www.ilga.gov/Legislation/BillStatus?DocNum=3673&GAID=18&DocTypeID=HB&SessionID=114)
- [BC ESG — California SB 253, SB 261 & AB 1305 Playbook](https://bcesg.org/california-sb-253-sb-261-compliance-playbook/)
- [BC ESG — NAIC TCFD Climate Risk Disclosure Survey Guide](https://bcesg.org/naic-climate-risk-disclosure-survey-tcfd-insurer-mandate-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.*