Property and Casualty News
January 2026
Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years we are always excited to share the latest sampling of insurance compliance related bulletins, regulations, and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!
ADJUSTERS
Iowa issued a bulletin outlining the financial responsibility requirements under SF 619 for public and independent adjusters, describing the acceptable forms such as surety bonds, E&O insurance, letters of credit, and alternative bonds to cover damages from errors, fraud, or violations of Iowa Code chapter 522C. Staff adjusters, appraisers, and umpires are exempt from these financial responsibility provisions, and the bulletin provides guidance on filing, recordkeeping, and verification. Bulletin 25-08
ARTIFICIAL INTELLIGENCE
Hawaii issued a memorandum providing guidance for insurers on the responsible use of Artificial Intelligence (AI) systems. Insurers must develop and maintain an AIS Program addressing governance, risk management, internal audit, transparency, and compliance with state laws prohibiting unfair trade practices, discrimination, and improper rates. The memorandum also requires documentation of AI systems, third-party due diligence, and validation processes. Memorandum 2025-13A
AUTOMOBILE INSURANCE
Louisiana mandates that insurers may not increase premiums or add surcharges for a policyholder’s first motor vehicle insurance lapse of 90 days or less under Act 476. Subsequent lapses may lead to rate increases, and policyholders with five or more years of continuous coverage after a lapse have their first subsequent lapse treated as a first lapse. The bulletin also defines “lapse in coverage” and specifies that withdrawal of inapplicable discounts is not considered a premium increase. Bulletin 2026-01
Oregon issued guidance on SB 840, which amends financial responsibility and suspension laws. The SR-22 filing requirement for uninsured driving convictions is reduced from three years to one year, and the mandatory one-year suspension for uninsured drivers involved in accidents is repealed, though SR-22 filings for accidents still apply. Insurers must notify customers of these changes and provide proof-of-coverage statements on request. Memorandum Dated 12/9/25
Pennsylvania announced that, effective July 1, 2026, the accident surcharge dollar threshold for private passenger auto insurance will increase to $2,350. The threshold applies to aggregate claim costs over three years for injury or property damage claims and must be filed for prior approval by April 1, 2026. Notice 2026-01
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE CHANGES
Alabama released a bulletin prohibiting insurers from canceling, non-renewing, or raising premiums on personal or commercial property and automobile policies solely due to claims from catastrophes, natural disasters, or weather-related events. Starting January 1, 2026, these rules apply to existing policies, with new policies and renewals also restricted from premium surcharges or rating tier changes. Exceptions are allowed for fraud, misrepresentation, or concealment, and insurers must update their rating manuals through SERFFSM. Bulletin 2025-08
CAPTIVES
Hawaii issued a memorandum implementing OPTins for authorized captive insurers, effective February 2, 2026, to enable electronic filing of Form CAP-001 and premium tax payments. The system streamlines submissions for taxes, license renewals, certificates, applications, and fees, replacing paper filings, with a nominal fee of $17.50 per transaction. Memorandum 2025-15C
Hawaii outlined in a memorandum the 2025 annual filing requirements for domestic risk retention captive insurance companies, with submissions due in 2026. Filings include NAIC financial statements, CAP-001 through CAP-006 forms, audit and internal control reports, cybersecurity certifications, and other state-required reports, with deadlines, electronic submission instructions via OPTins or email, and penalties for late or non-compliant filings. The memorandum also introduces OPTins for premium tax filings, details exemptions and relief provisions, and provides guidance on financial projections, service charges, and reporting for motor vehicle and workers’ compensation coverage. Memorandum 2025-17C
CONFIDENTIALITY / PRIVACY
Missouri issued guidance on the Insurance Data Security Act, clarifying cybersecurity event reporting, third-party service provider obligations, and the definition of “licensee.” Licensees must submit notifications of qualifying cybersecurity events electronically, and certain entities, including out-of-state purchasing groups, risk retention groups, and specific health and captive insurers, are excluded from the definition. The bulletin aligns Missouri’s implementation with NAIC Model Law 668. Bulletin 26-01
FLOOD INSURANCE
Hawaii released a memorandum informing insurance producers, administrators, and surplus lines brokers of FEMA’s updated Flood Insurance Rate Maps, effective June 10, 2026, which may place over 3,500 Oahu parcels into Special Flood Hazard Areas, triggering mandatory flood insurance and building requirements under ROH Chapter 21A. The memorandum advises industry professionals to notify clients of the changes, available NFIP discounts, and resources, including mitigation and Community Rating System discounts, to help property owners comply and manage financial obligations. Memorandum 2025-14A
HOLDING COMPANIES
Alabama requires domiciled insurers subject to group capital calculations to comply with updated filing requirements under NAIC Model Regulation No. 450. These requirements include provisions for exemptions, limited filings, and the authority of the Department to mandate filings from groups that previously qualified for exemptions or submitted limited filings. A hearing on February 5, 2026, will consider adopting new Rule 482-1-055-.18.2 to formalize these requirements. Bulletin 2026-01
LEGAL EXPENSE INSURANCE
New Jersey now classifies prepaid legal insurance plans as “legal insurance” under the New Jersey Legal Services Insurance Act, establishing licensing requirements for individuals and entities offering these plans. Limited lines prepaid legal insurance producer licenses are required for individuals selling the plans, while entities may sell through licensed representatives or employees under supervision, provided training programs cover plan provisions, consumer requirements, and applicable law. Licenses are issued and renewed biennially, with fees required, and plans involve members prepaying for specified legal services provided through contracted attorneys. AB 3802
MISCELLANEOUS PROPERTY / CASUALTY
Michigan published the updated list of municipalities participating in the Fire Insurance Withholding Program, effective February 5, 2026, indicating the applicable program section for each municipality and replacing prior editions. Municipalities may submit written changes to update their participation information. Notice Dated 1/5/26
Michigan set the 2026 fire insurance maximum escrow under Section 2845 at $16,383, reflecting annual adjustments based on the consumer price index. Municipalities may escrow 25 percent of fire insurance settlements for residential property losses, with the cap increasing from $16,025 in 2025. Bulletin 2025-27-INS
New Jersey released an order requiring all authorized property and casualty insurers to report changes to underwriting guidelines for homeowners and private passenger automobile policies implemented in 2026. Reports must be submitted within five days of changes, with prior orders establishing similar requirements for 2023–2025. The goal is to monitor market conditions and ensure compliance, with penalties possible for noncompliance. Submissions are confidential and should be emailed to market.analysis@dobi.nj.gov. Order A25-11
OMNIBUS LEGISLATION
Alaska issued a bulletin regarding implementation of Senate Bill 132, updating licensing and regulatory requirements for PBMs, TPAs, independent adjusters, and other insurance entities. The bulletin establishes new licensing, fee, compliance officer, and examination requirements, aligns terminology and procedures with national standards, and provides guidance on alias names in licensing systems. It also allows nonresident independent adjusters to obtain reciprocal licenses and eliminates certain distinctions and location requirements for licensees. Bulletin B 25-09 (Reissued)
PREMIUM TAX
Florida amended regulations on insurance premium taxes, fees, and surcharges. Insurers must calculate surcharges based on premiums reported on Statutory Page 14 of the Annual Statement, file an annual return by March 1, and remit taxes and surcharges using Forms DR-907 and DR-908. The amendments also clarify collection procedures, remove provisions on policy cancellation for nonpayment, and provide guidance for requesting forms electronically. Rule 12B-8.0012
New Hampshire issued a notice on 2025 premium tax return filings for property and casualty insurers and risk retention groups. Annual statements are due March 1, 2026, and premium tax returns are due March 15, 2026, with electronic filing available via TriTech. Taxable premiums include direct and renewal premiums, policy and service fees, and other considerations, while Medicare Advantage and Part D premiums are exempt; rates are 1.25% for property/casualty and 2% for accident/health. Informational Notice Dated 1/2/26
PROPERTY INSURANCE
California issued a bulletin enforcing a one-year moratorium on cancellations and non-renewals of residential property insurance following a state of emergency. This applies to properties in ZIP Codes 93512, 93514, 93529, and 93546 affected by the Pack Fire in Mono County, with insurers required to rescind notices and offer policy reinstatements or renewals. Bulletin 2025-17
REGULATORY REPORTING REQUIREMENTS
Florida updated its insurer reporting requirements, renaming the rule to “Filing procedures for market intelligence report” and making conforming changes. The amendment adopts a revised Form OIR-DO-1185, updating language on the Version, Instructions, and Contacts tabs, and requires insurers to submit company-specific information as outlined on the form. Rule 69O-137.009
REPORTS - ANNUAL / QUARTERLY STATEMENT
Connecticut now requires accredited reinsurers to submit annual financial statements and related filings electronically to the NAIC or via email, eliminating paper submissions. Certificates of accreditation automatically renew June 1, 2026, if all filings, including financial reports, actuarial opinions, management discussions, audit or trust reports, and ceding insurer lists, are completed by the specified deadlines. Trustees and pool managers must also submit required trust and participant documentation. Bulletin FS-4AR-25
Connecticut published a bulletin outlining the 2026 electronic filing requirements for annual and quarterly financial statements for all authorized insurers, surplus lines insurers, fraternal benefit societies, and health care centers. Annual statements are due March 1, 2026, and quarterly statements are due 45 days after each quarter, all filed electronically with the NAIC and following prescribed standards. Domestic insurers must include a Retention of Assets Statement, provide separate statements for general and separate accounts, and comply with reinsurance credit regulations. Bulletin FS-4-25
REPORTS - DATA CALLS & OTHER REPORTS
Florida amended its reporting requirements for residential property insurers, renaming the “Property Claims Litigation Data Call” to the “Property Claims Lifecycle Data Call.” Insurers must submit information using the updated Form OIR-B1-2222 electronically through the OIR portal, with annual reports for the preceding calendar year due on or before March 1. Rule 69O-171.011
SURPLUS LINES
Colorado amended its rules for surplus lines insurance issued by nonadmitted insurers, making updates to scope, definitions, procurement requirements, tax reporting, and incorporated materials. Changes include requiring documentation that coverage was not available from more than one admitted insurer, annual aggregate reporting through the SLIP system by March 1, and removal of certain definitions such as “annual statement” and “reporting period.” 3 CCR 702 Reg. 2-4-1
New Jersey updated the list of eligible surplus lines insurers authorized to operate in the state. The notice classifies insurers as foreign, domestic, or alien, and reflects recent additions, removals, name changes, and re-domiciliation. Notice Dated 1/1/26
TAX CREDITS
Florida’s Department of Revenue amended multitax credit regulations affecting, allowing insurers to apply a 100% tax credit for contributions against insurance premium tax under Section 624.509(1), while updating the list of allowable deductions to include additional credits such as the Home Away From Home Tax Credit and the Rural Community Investment Program credit. Rule 12-29.002
WORKERS' COMPENSATION
Alaska clarified death benefits for fatalities in 2026, specifying weekly payments for surviving spouses, children, and dependent relatives based on the deceased’s wage, with caps and minimums. Additional benefits include a death payment, funeral cost coverage, and a lump sum upon remarriage, while children may receive benefits until age 23 if dependent or in school. Bulletin WC 25-05
Alaska requires insurers, self-insured, and uninsured employers to file 2025 workers’ compensation reports electronically via EDI between January 1 and March 1, 2026, under the Department of Labor Bulletin dated January 5, 2026. The filings must include all cumulative claims, Second Injury Fund contributions, and Workers’ Safety and Compensation Administration Account fees, with reports considered filed only upon Transaction Accepted acknowledgment. The bulletin also provides guidance on penalties, audits, payment procedures, and reporting responsibilities. Bulletin WC 25-08
California’s Division of Workers’ Compensation launched a new online platform for submitting and tracking Public Records Act requests, providing a more accessible process. Individuals can register and submit requests through the Department of Industrial Relations Online Services Portal. DWC Release 2025-120
California’s Division of Workers’ Compensation updated the Ambulance Services section of the Official Medical Fee Schedule to align with Medicare payment changes, effective for services on or after January 1, 2026. The updated fee schedule is available on the DWC OMFS Ambulance Fee Schedule webpage. DWC Release 2025-119
Hawaii updated the 2026 Maximum Weekly Wage Base and Maximum Weekly Benefit Amount for Temporary Disability Insurance, Workers’ Compensation, and Prepaid Health Care programs. The bulletin sets TDI and WC wage bases and benefit caps, specifies employee withholding limits, and establishes the 2026 PHC minimum monthly wage and employer/employee contribution rules. These updates guide proper benefit calculations and compliance with withholding requirements. DCD Notice Dated 12/10/25
Illinois issued a bulletin to clarify workers’ compensation liability requirements under the Illinois Workers’ Compensation Act and Workers’ Occupational Disease Act. Carriers and producers must ensure nearly all employers, including those with part-time employees, have coverage with Illinois listed as a primary state on policies, or risk employer liability, reimbursement to the Injured Workers’ Benefit Fund, and penalties. Bulletin 2025-22
Massachusetts released a bulletin establishing the 2026 workers’ compensation mileage reimbursement rate for travel to medical and rehabilitation providers at 58.5 cents per mile. WC Mileage Reimbursement Rate 2026
Michigan published the 2026 State Average Weekly Wage (SAWW) at $1,333.88, establishing maximum and minimum workers’ compensation benefit rates. The maximum benefit is $1,201.00, while the minimum for death cases is $666.94, with standard calculations based on 2/3 SAWW and specific loss or total/permanent disability cases at 25 percent of SAWW. State Average Weekly Wage Chart Dated 1/5/26
Nebraska amended Rules 26, 32, and 47, updating medical fee schedules, reporting requirements, and lump sum settlement procedures. Rule 26 revises the inpatient hospital Medicare DRG codes; Rule 32 requires insurers and risk management pools to submit electronic reports within 10 days of policy changes; and Rule 47 updates the life expectancy tables to the 2023 U.S. Life Table and clarifies settlement application requirements. WC Ct Rule 26
Nevada notifies insurers and TPAs of a 2.3% cost-of-living adjustment to monthly Permanent Total Disability (PTD) and Survivor’s benefits, effective January 2026, as required under NRS 616C.473 and 616C.508. Notice Dated 12/13/25
New Mexico released the 2026 workers’ compensation and occupational disease disablement rates, based on the State Average Weekly Wage (SAWW). For 2026, the SAWW is $1,146.66, with minimum and maximum weekly benefits of $36.00 and $1,146.66, respectively. Lifetime benefits apply for permanent total disability, and total maximum compensation is $802,585 with funeral expenses capped at $7,500. WC Notice of Weekly Wage and Maximum
Oregon revised a bulletin to update the claims processing administrative cost factor to 19.49 percent. This factor applies to reimbursements for supplemental disability benefits, specific claim costs, and self-insured employer security deposits, and is used to calculate security deposits on unpaid losses. Bulletin 316 (Revised)