Property and Casualty News

March 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!


CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE

Indiana requires insurers that rely solely on aerial images to nonrenew a policy to provide policyholders with access to the images used, ensure the photos were taken within the past 24 months, and establish a contact point and appeal process for reviewing the decision. The law also requires insurers to give policyholders at least 60 days to correct identified conditions and mandates that insurers offer renewal if the defects are cured, unless the insurer has another unrelated reason for nonrenewal.     HB 1260, IC 27-7-12-6.5


CLAIMS / CLAIMS ISSUES

Vermont issues a revised bulletin addressing the expanded use of virtual claims adjustment systems across multiple insurance lines. The bulletin reminds insurers that they must still conduct reasonable investigations and make prompt, fair claim settlements, noting that photos and videos may not fully capture damage. Insurers must provide an in-person inspection by a licensed adjuster when requested by the claimant or when virtual adjustment is inappropriate, particularly when hidden or non-visible damage may exist.     Bulletin 206 (Revised)

Virginia issues guidance clarifying insurers’ responsibilities when calculating depreciation to determine actual cash value (ACV) in property insurance claims. The Bureau of Insurance reaffirms its longstanding position on whether labor expenses and other nontangible items may be depreciated when calculating ACV under policies that include ACV or replacement cost loss settlement provisions. Forms that include language stating that depreciation includes labor and other intangibles (taxes, fees, O&P) must be re-filed removing that language as soon as possible. Companies do not have to re-file forms to state what is not included in depreciation.     Administrative Letter 2025-06 dated 2/17/26


COMPLAINTS

Oklahoma adopted the NAIC’s SBS External Company Complaint Portal, effective April 1, 2026. The system improves communication between the Oklahoma Insurance Department and licensed insurers while streamlining the handling of consumer complaints and provider grievances. Through the SBS dashboard, companies can manage cases, exchange messages, and upload supporting documents directly.     Special Notice dated 3/9/26


CROP HAIL INSURANCE

South Dakota issued a bulletin outlining requirements for insurers marketing crop hail insurance in the state and clarifies that crop hail insurance includes policies providing crop hail coverage, companion hail, and supplemental crop products not subsidized or reinsured by the Federal Crop Insurance Corporation. The bulletin replaces all prior crop hail bulletins and requires insurers to file new or revised rates and forms each year.     Bulletin 26-01


CYBERSECURITY

Delaware reminds all entities engaged in the insurance business of their obligations under the Delaware Insurance Data Security Act which strengthens protections for consumers’ nonpublic information and personal data. Delaware requires insurers, intermediaries, producers, brokers, agents, underwriters, and contractors to maintain information security programs, conduct risk assessments, investigate cybersecurity events, notify affected parties, and provide one year of free credit monitoring to impacted consumers.     Universally Applicable Bulletin 5 (Reissued)


FINANCIAL REGULATION

Arkansas issued a bulletin stating that the Insurance Commissioner intends to adopt amendments, revisions, or modifications to the NAIC Accounting Practices and Procedures Manual (APPM) as of March 2026. The bulletin notifies domestic insurers and other domestic insuring entities that, pursuant to Ark. Code Ann. § 23-63-613, they must use the latest edition of the APPM no earlier than eight months after statutory notice is issued.    Bulletin 3-2026


GUARANTY ASSOCIATION

Florida announces that the Florida Insurance Guaranty Association (FIGA) will end the 1 percent emergency assessment (2023A) effective October 1, 2026. Florida requires insurers to remove the assessment from all new and renewal policies effective after September 30, 2026, while FIGA will continue collecting it on policies dated on or before that date.     2026 FIGA Assessment Update


HOLDING COMPANIES

Ohio updated regulations governing insurance holding company systems, including requirements for acquiring control of a domestic insurer through Form A filings. The rule also revises annual registration and reporting requirements for insurers within a holding company system (Forms B, C, and F), sets forth prior notice requirements for certain affiliated transactions (Form D), and updates standards for managing general agent licensing, examination work paper definitions, and conditions for ceding insurers to receive credit for reinsurance.     Rule 3901-3-01


LIABILITY INSURANCE

Indiana enacted a new Insurance Code chapter prohibiting insurers from requiring an insured or prospective insured to post or display a gun-free zone notice. The law applies to property and casualty insurance policies issued, delivered, entered into, renewed, or amended after June 30, 2026, and defines the terms “gun-free zone notice,” “insured,” “insurer,” and “property and casualty insurance.”     HB 1274


MARKET CONDUCT EXAMINATIONS

Missouri amended regulation 20 CSR 100-8.040 governing recordkeeping requirements for insurers. The amendment replaces the prior 10-day response deadline with a flexible timeframe set by the examiner, which must allow at least 30 calendar days to respond.     20 CSR 100-8.040


MISCELLANEOUS

Maryland amends regulations to implement changes to the state’s sales and use tax laws enacted during the 2025 legislative session. The revisions update administration of sales and use tax, including admissions and amusement taxes, and require individuals providing personal, professional, or insurance services to collect and remit tax on independent sales of tangible personal property, digital codes, digital products, or taxable services unless exempt.     COMAR 03.06.01.01

Michigan published an updated list of municipalities participating in the Fire Insurance Withholding Program through the Department of Insurance and Financial Services. The updated list applies to municipalities newly participating in the program on or after April 1, 2026.     Notice of March 1, 2026

Utah adopted Rule R590-291 to identify the circumstances under which a property and casualty insurer may use fire hazard data other than the wildfire risk assessment mapping tool maintained by the Division of Forestry, Fire, and State Lands.     Rule R590-291-1


PREMIUM ISSUES

Louisiana requires all authorized property and casualty insurers to offer premium discounts for residential properties that obtain an IBHS FORTIFIED designation under Regulation 136. The rule encourages hurricane mitigation measures to reduce losses and improve resilience. Discounts are to be applied to all new and renewed residential property policies issued on or after January 1, 2027.     Bulletin 2026-04


PROPERTY INSURANCE

Colorado issued guidance for insurers regarding the required annual written notice to policyholders on risk scores and mitigation discounts. This information must also be disclosed to applicants at the time of application. The notice must include any wildfire risk scoring or classification systems used to underwrite or price residential property policies, including master policies for multifamily housing.     Bulletin B-5.56


REPORTS - DATA CALLS & OTHER REPORTS

North Carolina issued a bulletin concerning annual reporting requirements for insurance covering loss to residential real property with not more than four housing units. All data from homeowners insurance policies is to be reported, including the consent to rate data.     Bulletin Number 26-B-05

North Carolina issued a bulletin concerning the semi-annual reporting requirements for Consent to Rate policies issued between July 1, 2025, and December 31, 2025,     Bulletin Number 26-B-06


SERVICE CONTRACTS / WARRANTY INSURANCE

Oklahoma amended the Service Warranty Act to revise the administrative fee structure applied to provider fees and assessments collected by service warranty associations and insurers. The changes adjust how administrative fees are calculated and applied to warranties.     HB 1085


STANDARD VALUATION LAW

Idaho directs authorized insurers to use revised NAIC accounting and valuation manuals when preparing their 2026 quarterly and annual financial statements.     Bulletin 26-01


SURPLUS LINES

Colorado issued updated guidance for surplus lines brokers who independently procure non-admitted insurance on reporting and paying premium taxes. Colorado directs these parties to comply with state premium-tax laws using the Florida Surplus Lines SLIP+ for States filing platform.     Revised Bulletin B-2.10

Louisiana issued guidance regarding adoption of SLIP+ for reporting and payment of surplus lines taxes.     Bulletin 2026-03

Louisiana issues an advisory letter requiring surplus lines insurers to provide policyholders with at least 30 days’ advance written notice before canceling or nonrenewing commercial or residential property and casualty policies. The guidance applies to surplus lines insurers issuing policies in the state and clarifies that shorter notice periods are allowed only when permitted by law, such as for nonpayment of premium.     Advisory Letter 2026-01

Montana clarifies that, under section 33-2-307(3) of the Montana Code Annotated, surplus lines insurance producers may place business with any alien insurer listed on the NAIC’s Quarterly Listing of Alien Insurers. The Department of Insurance also notes that the NAIC has updated the name of this listing and provides a link for producers to access the updated list.     Eligible Surplus Lines Companies dated 2/23/26

New Jersey updated its list of eligible surplus lines insurers, organizing companies into foreign, domestic, and alien categories and identifying additions, withdrawals, and updated identification numbers. The bulletin notes several insurers added in early 2026, the withdrawal of one insurer at the end of 2025, and updated identification numbers for certain alien insurers, while confirming that no name changes or redomestications occurred.     Notice of February 12, 2026


TRADE PRACTICES

Indiana enacts an emergency measure prohibiting the operation of virtual currency kiosks in the state. The bill authorizes the Attorney General to treat violations as deceptive consumer sales acts and allows courts to impose additional penalties, including forfeiture of user fees collected during the violation and seizure of any kiosks operated in Indiana.     HB 1116


WORKERS' COMPENSATION

Indiana updates its workers’ compensation and insurance laws to integrate students in work-based learning programs by redefining “employee” and “employer.” The law establishes benefit rules for both paid and unpaid student workers and adds a chapter requiring objective, age-neutral underwriting standards for coverage related to such programs.     HB 1098

Massachusetts published an updated workers’ compensation mileage reimbursement rate for injured employees traveling to medical and rehabilitation providers.     Mileage Reimbursement Rate March 2026

Nevada issued a notice to remind insurers and third-party administrators that all workers’ compensation claim denial notices must notify the Division of Industrial Relations’ Workers’ Compensation Section by email in PDF format, with “Denial” included in the file name and subject line, and that paper notices should not be mailed.     Important Reminder dated 2/18/26