Property & Casualty News
December 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 LICENSING AND APPOINTMENT
Louisiana's Insurance Department updated its producer and adjuster license renewal procedures, fees, filing methods, and standards of conduct, effective January 2026. Key changes include renewal schedules based on license number, updated fees with late penalties, options to file renewals via the Industry Access Portal or NIPR, continuing education compliance requirements, and acknowledgment of claims adjuster standards of conduct. Non-renewed lines may be reactivated within two years with continuing education, or after two years by meeting exam requirements. Notice Dated 11/28/25
AUTOMOBILE INSURANCE
Colorado released guidance on submitting the interim progress report required under Regulation 10-1-1 for insurers using external consumer data or models to write Private Passenger Auto. Insurers may choose their own format but are encouraged to include an executive summary, progress updates, challenges, solutions, and expected completion dates. Bulletin B-10.005
Nevada has revised its code to permit short-term vehicle lessors to request, and no longer require, proof of certain insurance as a condition for leasing a passenger car. SB 1
CAPTIVES
Arizona amended its regulations to add new fees and defined processing timeframes for captive insurers seeking a Certificate of Dormancy, effective January 4, 2026. The updates introduce specific dormancy application, renewal, and surrender fees, clarify examination cost obligations, and establish a 60-day total licensing timeframe for dormancy-related filings. R20-6-708 Table A
DISASTER / CATASTROPHIC EVENT
California's Governor issued an order expanding and clarifying prior wildfire-related directives to speed rebuilding after the fires in Los Angeles and Ventura Counties, including suspending certain 2025 building code requirements to reduce reconstruction costs while preserving insurance eligibility for code-upgrade coverage. Executive Order N-37-25
FILING REQUIREMENTS / PROCEDURES
District of Columbia released filing compliance checklists for 2024 and 2025 for life, accident and health; property and casualty; health entities; and title companies. The guidance clarifies that companies not offering or writing medical stop-loss coverage are exempt from filing the DC Stop Loss Reporting Form, and that the instructions do not apply to DC captive insurers. Notice Dated 11/8/25
FILINGS: PROPERTY / CASUALTY
Hawaii announced the reorganization of the Rate and Policy Analysis Branch into two specialized units: the Life and Accident & Health Filings Branch and the Property and Casualty Filings Branch. This restructuring aims to improve review timeliness and regulatory oversight. Memorandum 2025-12R
Hawaii's Insurance Department extended the comment period for revised Property and Casualty rate filing procedures, initially issued in Memorandum 2025-10R, to December 31, 2025. The updated General Requirements and Filing Instructions modernize the P&C rate filing process, with compliance required by February 1, 2026, though insurers may begin using the new forms immediately. Memorandum 2025-11R
Louisiana announced the availability of the Confidentiality Affidavit referenced in Advisory Letter 2025-04, allowing insurers to designate rate filing documents as confidential, proprietary, or trade secret. Submitted affidavits will be reviewed by the LDI, and if approved, an attestation will be issued for inclusion in the filing. Bulletin 2025-06
Nevada's Insurance Department has established a Flex-Rated Filing Program for property insurance on real property, effective January 1, 2026. Insurers may use this program as an alternative to standard rate filings under NRS 686B.070 by filing through SERFF and indicating participation. Bulletin 25-005
HOLDING COMPANIES
Mississippi has amended its insurance holding company regulations to align with the NAIC Model. Changes revise minimum requirements for cost-sharing and management service agreements, establish provisions for group capital calculations, including exemptions and limited filings for qualifying systems, and renumber and update sections on Adequacy of Surplus. All new and renewal reinsurance transactions from July 1, 2017, forward must comply with these requirements. Regulation 19-1-20.19
Oregon amended OAR Chapter 836 to update definitions, expand prior notice requirements for transactions involving cost-sharing and management services, and establish rules for annual group capital calculations for insurance holding company systems. The amendments clarify ownership and control of books, records, and data, and specify affiliate obligations during supervision or receivership. The regulation also sets standards for non-U.S. jurisdictions that “recognize and accept” the group capital calculation. OAR 836-027-0005 +
LIABILITY INSURANCE
District of Columbia has adopted the Rental Amendment Act of 2025 to revise tenant and housing provider protections. Revisions include expedited court review for evictions related to dangerous crimes, discretionary dismissal of claims based on equities, and a reduction of the pre-filing notice period for nonpayment evictions from 30 to 10 days. The Act also updates procedures for delivering pre-filing notice. A lessee is required to maintain personal injury and property damage liability insurance on the property that names the owner as the additional insured. B 164
MISCELLANEOUS
Michigan's Insurance Department published an updated list of municipalities participating in the Fire Insurance Withholding Program, effective January 1, 2026. The list specifies the program section for each municipality and supersedes prior editions, with changes accepted in writing from participating municipalities. Notice Dated 12/1/25
New Mexico issued an amended bulletin, replacing Bulletin 2021-014, to provide the correct “Notification of Intent to Offer Value-Added Products and Services Filing Instructions and Form.” The bulletin clarifies regulations under Section 59A-16-17 NMSA 1978 regarding permissible value-added offerings while maintaining prohibitions on inducements in insurance contracts. Bulletin 2025-006
PERSONAL LINES INSURANCE
North Carolina’s Rate Bureau announced the availability of materials for the 2027 Homeowners Policy Program, which will replace the current program for policies effective June 1, 2027. The bulletin also corrects a prior circular letter by including Form HO 06 43 03 22 Cosmetic Damage Exclusion-Windstorm or Hail, which had been omitted. Circular Letter P-25-4
PHARMACY BENEFIT MANAGERS
Alaska issued a bulletin to guide implementation of SB 132, which overhauls licensing and regulatory requirements for PBMs, TPAs, Independent Adjusters, and other entities effective January 1, 2026. The bulletin outlines new fees, expanded licensing obligations, updated definitions, national-standard uniformity changes, and revised compliance officer rules. It also clarifies filing requirements, examination costs, and the use of alias names in SBS. Bulletin B 25-09
Illinois updated its insurance code to expand preventive health and vaccine coverage, strengthen PBM contract, reporting, and licensure requirements, clarify unfair insurance practices, revise pharmacy practice definitions, and establish a pharmacy support grant program to improve access in underserved areas. The amendments include detailed provisions on coverage without cost-sharing, PBM pricing and drug access restrictions, reporting and refund obligations, and annual reporting on pharmacy grant distribution. HB 767
Kentucky has amended its insurance code to enhance PBM licensure, renewal, and oversight requirements. Specific changes include a $10,000 registration fee (with workers’ compensation–only PBMs exempt), clarified renewal procedures and deadlines, a $500 late renewal penalty, and a $1,000,000 minimum financial responsibility requirement via insurance or surety bond. The regulation also incorporates the updated PBM License Application Form PBM (January 2025). 806 KAR 9:360
PROPERTY INSURANCE
Delaware reminds carriers of their obligations to accurately report geographic premium allocations and fire department payments, citing ongoing concerns about inconsistent filings. The bulletin reiterates requirements previously outlined in Bulletins 55, 9, and 151, including GIS use, premium allocation standards, and HB 371 updates, and directs carriers to immediately ensure internal processes support full compliance. Domestic-Foreign Insurers Bulletin 151
REPORTS - ANNUAL / QUARTERLY STATEMENT
Kansas issued NAIC instructions and calculations effective for calendar year 2026, including risk-based capital (RBC) instructions, the Financial Analysis Handbook, group capital calculation instructions, and the NAIC liquidity stress test framework. These requirements apply to filings as of December 31, 2025, for annual, quarterly, and group capital reports, as well as liquidity stress test submissions. Notice of NAIC Instructions 2026
REPORTS - DATA CALLS & OTHER REPORTS
Louisiana released a bulletin requiring all admitted commercial and private passenger auto insurers to submit data covering 2015–2024 via the NAIC Reporting Portal. Certain specialty insurers are excluded, and submitted data is treated as confidential. Bulletin 2025-08
Louisiana requires that the Annual Premium Tax Statement (Form 1061) and Annual Municipal Premium and Tax Report (Form 1076) be filed online through the Industry Access Portal. Companies claiming investment or military tax credits must also submit Forms 1068C and 1425, respectively, along with supporting documents. Notice Dated 11/14/25
SURPLUS LINES
California's Department of Insurance updated the 2025 Export List to add Commercial Cannabis Related Operations and revise Foster Family liability categories, identifying coverages that may be placed with non-admitted insurers without meeting most section 1763 requirements. The bulletin reiterates that non-listed risks may still be exportable with proper diligent search documentation and outlines the range of coverages included on the updated list. Bulletin 2025-16
Montana published an updated list of surplus lines companies eligible in the state, including each company’s name, NAIC code, and state of domicile. Surplus lines producers may also place insurance with alien companies listed on the NAIC’s “Quarterly Listing of Alien Insurers,” per MCA 33-2-307(3). Notice Dated 11/19/25
New Jersey's Insurance Department issued updated lists of eligible foreign and domestic surplus lines insurers, as well as eligible alien surplus lines insurers per the NAIC Quarterly Listing of Alien Insurers, reflecting additions, deletions, name changes, and redomiciled companies. Notice Dated 11/13/25
WORKERS' COMPENSATION
California's Division of Workers’ Compensation announced updated 2026 temporary total disability rates, with the minimum increasing to $264.61 and the maximum to $1,764.11 per week. These SAWW-based adjustments also apply to life pension and permanent total disability benefits for eligible workers. DWC Release 2025-116
Florida's Insurance Department announced that the maximum weekly workers’ compensation rate for injuries occurring on or after January 1, 2026, will be $1,358, based on a statewide average weekly wage of $1,357.95 for the year ending June 30, 2025. This applies to all carriers, self-insured employers, and third-party administrators. Informational Bulletin Dated 12/2/25
Idaho's Industrial Commission published the 2026 Workers’ Compensation Benefits table, establishing an Annual Average Statewide Wage of $1,135 and providing compensation rates as percentages of the Average Weekly Wage. The notice includes instructions for calculating AWW from monthly salaries and guidance for determining rates based on the year of injury. WC Notice of Weekly Compensation Rate (2026) Rev.
Minnesota published the 2025 State of the Market Report, which analyzes Minnesota’s workers’ compensation market. The report notes a 2% decline in premium volume in 2024, a nearly 10% increase in average indemnity costs per claim, and stable net case reserves due to ongoing reserve releases. WC Circular Letter 25-1869
Missouri announced the 2026 workers’ compensation rates following NCCI’s proposed 1.3% increase in loss costs, the second rise in six years due to historically low workplace injury frequency. Industry-specific changes include Manufacturing (+2.9%), Contracting (+0.3%), Office & Clerical (+2.1%), Goods & Services (+0.4%), and Miscellaneous (+1.8%). Notice Dated 11/18/25
Nebraska announced that, effective January 1, 2026, the maximum weekly income benefit for work-related injuries and illnesses will increase to $1,166, while the minimum remains $49. Benefits are calculated at 100% of the state average weekly wage, rounded up. WC Notice Dated 11/18/25
Nevada released guidance addressing SB 317, which updates the workers' compensation system. The guidance addresses topics including physical office requirements, self-insured employer claims administration, maximum employee benefit calculations, temporary partial disability payments, subsequent injury accounts, administrative fines, delegation of care to physician assistants, drug formulary updates, mental health provider lists, and related claims administration requirements. Notice dated November 12, 2025
New Jersey announced 2026 workers’ compensation benefit rates, effective January 1, 2026. Maximum benefits for Temporary Disability, Permanent Partial Disability, Total Disability, and Death Benefits are $1,199, with minimums of $320 for Temporary and Total Disability and $35 for Permanent Partial Disability; Temporary and Total Disability benefits are calculated at 70% of wages, while Permanent Partial Disability varies by injury type and severity. LWD Notice Dated 11/25/25
North Carolina approved filing WC2025-04 from the North Carolina Rate Bureau, revising the Basic Manual for Workers' Compensation and Employers’ Liability. Producer fees for minimum premium policies are now based on the full minimum premium including the expense constant, and premium-financed residual market policies must pay 100% of the estimated annual premium upfront. These changes take effect January 1, 2026. Circular Letter C-25-12
United States CMS issued an alert maintaining recovery thresholds of $750 for physical trauma-based liability insurance, no-fault insurance, and workers’ compensation settlements where the payer has no ongoing medical responsibility, while clarifying that the threshold does not apply to ingestion, implantation, or exposure claims. CMS Notice Dated 11/18/25 (3)
United States CMS released the Workers' Compensation Medicare Set-Aside (WCMSA) Fiscal Year Statistics 2025 report on November 26, 2025, providing data on WCMSA activity and Workers’ Compensation Review Contractor values for fiscal year 2025. CMS Notice Dated 11/26/25