Property and Casualty News
October 2025
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!
AGENT / PRODUCER CONTINUING EDUCATION
South Dakota repealed producer licensing rule 20:06:18:09, which previously limited licensees to receiving no more than half of their required continuing education credits from courses sponsored by a single insurance company within any two-year period. 20:06:18:09
ARTIFICIAL INTELLIGENCE
California enacted the Transparency in Frontier Artificial Intelligence Act, establishing mandatory transparency, incident reporting, and whistleblower protections for large frontier AI developers to mitigate catastrophic risks while supporting innovation. The law requires developers to implement risk frameworks, report critical safety incidents, and protect employees who disclose violations, with enforcement authority and civil penalties up to $1 million per violation. SB 53
AUTOMOBILE INSURANCE
California lowered its uninsured and underinsured motorist coverage requirements for transportation network companies (TNCs) from $1 million to $60,000 per person and $300,000 per incident while a passenger is in the vehicle. The bill makes TNCs solely responsible for maintaining this coverage and requires that any resulting insurance cost savings be reinvested to support the economic welfare of drivers and riders. SB 371
Delaware established new regulations for non-consensual towing of motor vehicles weighing 5,000 pounds or less from private and public parking areas. The new provisions set strict pre-towing requirements, cap towing and storage fees, regulate storage facility standards, and provide legal remedies for improper towing. HB 67
Missouri issued a bulletin directing auto insurers to register with the new Missouri Insurance Verification System (MOIVS), as part of the state’s Uninsured Motorist Program. Insurers must begin system testing by January 15, 2026, with transition to full production by March 16, 2026. Bulletin 25-09
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
California issued a bulletin enforcing a mandatory one-year moratorium on cancellations and non-renewals of residential property insurance policies in areas affected by the TCU September Complex Fire. Insurers are prohibited from dropping coverage due to wildfire risk for properties in specified ZIP Codes and must reinstate or renew any policies canceled since the declaration. The moratorium applies to homeowners’, condo, mobile home, and renters’ policies. Bulletin 2025-13
CLAIMS / CLAIMS ISSUES
Michigan released a bulletin warning auto insurers against improper claims practices, including delayed investigations, underpayments, and pressuring claimants into title transfers without fair settlements. The Department of Insurance and Financial Services (DIFS) reminds insurers they must comply with prompt, fair claims handling or face regulatory penalties. Bulletin 2025-19-INS
Wisconsin reminds property and casualty insurers to process storm-related claims promptly following the August 2025 floods in Southeast Wisconsin. Insurers must affirm or deny claims within 30 days, enabling consumers to meet FEMA’s November 12 disaster aid deadline. Bulletin Dated 10/7/25
COMMERCIAL LINES INSURANCE
California strengthened its oil spill prevention by requiring facilities that could impact state waters to obtain a certificate of financial responsibility. The adopted bill mandates public disclosure of certificate applications and directs the Office of Spill Prevention and Response to conduct a public review process every 10 years, starting in 2027, to update financial assurance requirements for oil spill response. SB 237
Michigan published an updated list of municipalities participating in the Fire Insurance Withholding Program. The list identifies each municipality's participation type and replaces previous versions. Insurers must be notified at least 30 days in advance of any new municipal participation. Notice Dated 10/1/25
CREDIT INSURANCE
Illinois now requires credit insurance refunds under the Consumer Installment Loan Act to be calculated strictly per the Department of Insurance’s rule 50 Ill. Adm. Code 1053.10, replacing the previous broader refund method standard. 38 Ill. Adm. Code 110.170
South Carolina set 2026 credit property insurance rates. The rates are based on loan amounts, with notable premiums like 0.45% for Automobile Fire and Theft and 5.81% for Household Goods – Single Interest. Insurers must submit required reports and notify the Department by December 1, 2025, if using these rates or lower. Order 2025-005
CYBERSECURITY
California amended its Civil Code to require businesses to disclose data breaches within 30 calendar days of discovery, with limited allowances for law enforcement delays or system restoration efforts. The amendment also updates reporting requirements, mandating that businesses notify the Attorney General within 15 days if a breach affects more than 500 California residents. SB 446
California issued a notice reinforcing mandatory reporting requirements for data breaches involving personal information of California residents, applying to all entities engaged in the insurance business. The notice emphasizes compliance with the Insurance Information and Privacy Protection Act requiring timely notification of breaches, including those involving affiliates or vendors, and submission of breach notices to both the Attorney General and the DOI. Notice Dated 9/30/25
New York DFS warns regulated entities about active cyberattacks exploiting zero-day vulnerabilities in Cisco ASA and Firepower devices, urging immediate remediation per CISA guidance. Entities must identify affected devices, apply updates promptly, disconnect unsupported hardware by set deadlines, and report incidents to DFS if compromised. Industry Letter Dated 9/26/25
DISCRIMINATION
Texas issued a bulletin implementing SB 1238, which prohibits insurers from discriminating against widowed individuals in coverage, options, or rates compared to married individuals. This applies to all policies delivered, issued, or renewed on or after September 1, 2025. Bulletin B-0014-25
FILING REQUIREMENTS / PROCEDURES
Michigan reminds reciprocal insurance exchanges of their continuous filing obligations under MCL 500.7210. Companies with outdated filings must submit updated information via SERFF by October 31, 2025, including required contracts and agreements. Bulletin 2025-21-INS
MISCELLANEOUS PROPERTY / CASUALTY
Kansas' Attorney General clarified that the Public Adjusters Licensing Act applies only to commercial lines insurance contracts and does not regulate or prohibit public adjusting for residential insurance claims. While unlicensed individuals may assist with residential claims, they must still comply with consumer protection laws and avoid unauthorized legal practice. The Act’s scope remains limited to licensing public adjusters for commercial insurance claims. Attorney General Opinion 2025-22
Washington urges property and casualty insurers to provide a minimum 30-day grace period for federal employees affected by the ongoing government shutdown. Insurers are encouraged to waive late fees, avoid cancellations, and clearly communicate flexible payment options. The bulletin emphasizes protecting coverage for the approximately 80,000 impacted federal workers in the state. Notice Dated 10/6/25
PHARMACY BENEFIT MANAGERS
Iowa issued a bulletin to guide implementation of SF 383 that regulates Pharmacy Benefit Managers (PBMs) in prescription drug practices. The law mandates NADAC-based reimbursements, pass-through pricing, rebate transparency, and prohibits discriminatory or deceptive practices. PBMs must also comply with new appeal processes and cost-sharing rules. Bulletin 25-06
Massachusetts now requires all Pharmacy Benefit Managers (PBMs) to be licensed by the Division of Insurance starting January 1, 2026. The initial one-year license costs $8,334, and future three-year licenses will cost $25,000. Bulletin 2025-04
North Carolina adopted new PBM regulations establishing licensing, fees, financial responsibility, claims processing, and operational standards to strengthen oversight and compliance. Key rules include application requirements, financial reporting, solvency criteria, claims handling protocols, and administrative governance for PBMs. 11 NCAC 24 .0101
PROPERTY INSURANCE
California reminds property and casualty insurers of their obligations under the "efficient proximate cause" doctrine, which requires coverage for damages like mudslides or flooding if caused by a wildfire, a covered peril. Insurers must not deny such claims without a thorough investigation and must comply with established legal standards when handling post-wildfire damage claims. Notice Dated 9/19/25
REPORTS - DATA CALLS & OTHER REPORTS
North Carolina’s Property and Casualty Division requires insurers offering nonfleet private passenger motor vehicle physical damage and certain homeowners insurance policies under Consent to Rate provisions to submit semi-annual reports by November 20, 2025. Bulletin 25-B-13
SURPLUS LINES
Connecticut published an updated list identifying all licensed insurance companies, approved/accredited reinsurers, and surplus lines insurers operating in the state. The list includes each company's name, type, domicile and state, NAIC code, and NAIC group number. Interested parties are advised to use the State Based System Lookup Tool for more detailed information. Notice Dated 9/30/25
Georgia launched a new Compliance Review Program for surplus lines brokers to verify adherence to filing and tax remittance requirements. The program includes routine, random, or issue-triggered reviews, and emphasizes education, error reduction, and market integrity. Brokers will receive advance notice, must provide key records, and are expected to respond to findings within 14 days. Bulletin 25-EX-3
THIRD PARTY ADMINISTRATORS
Nevada requires third-party administrators (TPAs) to have written agreements with insurers that comply with specific statutory provisions, prohibiting subcontracting of workers’ compensation administration to a second TPA. TPAs must also provide insured parties with insurer-approved written notice detailing the relationships between the insurer, TPA, and insured. Bulletin 25-001
WORKERS' COMPENSATION
Arkansas released updated workers’ compensation rates for 2026, setting the maximum weekly benefit at $953.00 for Total Disability and $715.00 for Permanent Partial Disability, based on 85% of the state’s Average Weekly Wage. Notice 2000-1 Updated 10/1/25
California’s Division of Workers' Compensation updated the Official Medical Fee Schedule for physician and non-physician practitioner services. The update incorporates the CMS Medicare National Physician Fee Schedule Relative Value File (RVU25D) and revised procedure edits. DWC Release 2025-91
Colorado amended the Medical Fee Schedule to align reimbursement rates and procedures with Medicare and Medicaid standards, updating billing codes and documentation requirements. The amendments also update related exhibits and introduce new standards for prior authorization, provider procedures, and administrative processes. 7 CCR 1191-3
Connecticut’s Workers' Compensation Commission announced that specific forms and documents may now be submitted electronically through the enhanced GovQA System. While electronic submission is optional, this update aims to streamline processes for insurers, claimants, attorneys, and other stakeholders. The new system allows secure online submission of various claim-related and administrative forms, though parties must still provide physical copies to other involved parties where required. Memorandum 2025-09
Connecticut's Workers' Compensation Commission published an updated Authorization for Release of Medical Records form that complies with HIPAA and the state’s Reproductive Rights Shield Law. While use of the revised form is optional, the WCC encourages stakeholders to review and utilize it as needed in workers’ compensation cases. The form is available on the WCC website. Memorandum 2025-07
Idaho’s Industrial Commission released the 2026 workers’ compensation survivor death benefits, based on the state’s Average Weekly Wage of $1,135.00. The update includes historical data since 2017 and clarifies that certain family members—such as parents, siblings, grandparents, and grandchildren—may qualify for benefits if they were financially dependent on the deceased worker. WC Survivor Death Benefits 2026
Indiana approved the 2026 Advisory Rate Filing, which reduces advisory loss costs by 6.1% and both advisory and assigned risk rates by 5.8%, effective January 1, 2026. These changes reflect continued declines in lost time claim frequency and average claim costs across the state. Rate impacts vary by classification within five industry groups. Circular 2025-08
Kentucky set the 2026 discount rate for lump-sum workers’ compensation settlements at 3.75% for weekly payments over $40 and 4.25% for payments of $40 or less. These rates are based on the 10-year U.S. Treasury Note rate as of August 1, 2025. The updated rates apply to all lump-sum settlements finalized in 2026. Order Dated 9/29/25
Massachusetts updated its Indemnity Data Call requirements, adding six new data fields that workers’ compensation insurers must report starting with Q4 2025 data, due by the end of Q1 2026. Circular Letter 2448
Nevada has adopted the Official Disability Guidelines (ODG) Drug Formulary for its workers' compensation system, with full implementation by July 1, 2027. The formulary applies to non-emergency outpatient services and allows appeals for denied non-formulary drugs, aiming to improve efficiency, outcomes, and timely care for injured workers. Notice Dated 9/17/25
Virginia's Workers' Compensation Commission will begin enforcing civil penalties starting January 1, 2026, for insurers that fail to submit Form 26A by the January 31 deadline, as required by Va. Code § 65.2-902(a). Late filings will incur a minimum $500 fine. WC News Dated 10/2/25 (2)