Zoning In - Spring 2026

Northeast Zone

Maryland

Bulletin 26-11, dated April 27, 2026, and titled “Requirements for Consumer Cancellation of Public Adjuster Contracts,” advises that “public adjusters may not require, or add provisions in their contracts that require, more onerous burdens upon consumers who wish to cancel their contracts within the allotted time. Public adjusters may not require consumers to use certified mail or other more onerous means than the statute allows in order to cancel their public adjuster contract.” The Bulletin also includes specific existing requirements including mandatory contract language regarding insured contract cancellation rights.

New Jersey

Bulletin 26-02, dated April 1, 2026, states that its purpose is to provide guidance regarding N.J.S.A. 17:46E-1 to -9, the Travel Insurance Act (the “Act”), which became effective on April 18, 2026. The Act applies to travel insurance policies that cover any New Jersey resident, and are sold, solicited, negotiated, or offered in New Jersey, and policies and certificates that are delivered or issued for delivery in New Jersey. N.J.S.A. 17:46E-2. In advance of future regulations being adopted, insurance producers, travel retailers, travel administrators, and insurers must still comply with the Act. Requirements covered in this Bulletin include those applicable to producer license requirements, travel insurance producer responsibilities, a “Designated Responsible Producer,” a register of travel retailers, the training and oversight of travel retailers, travel retailer responsibilities, the provision of certain materials to prospective purchasers and purchasers of travel insurance, prohibited conduct, insurer responsibilities, the classification and filing of rates, rules, and forms, and premium tax.

Pennsylvania

Notice 2026-07, dated April 11, 2026, addresses “Property and casualty rate, rule and policy form filing modernization” and deregulation of certain lines. The Notice provides that rate, rule and policy form filing requirements apply only to the following types of insurance as of the date of this notice: All Types and Kinds of Personal Risk Insurance, Commercial Property, Commercial Flood—Rates and Rules Only, Farmowners, Medical Professional Liability, Workers' Compensation, Commercial General Liability, Businessowners, Commercial Cyber Liability, Title, Commercial Auto, Day Care Centers, and Lender-Placed Insurance Products.

The Commissioner has deregulated all other types and kinds of property and casualty insurance from rate, rule and policy form filing requirements. The Notice further explains that this is an expansion of the prior deregulation of certain commercial lines filings set forth in previous Pennsylvania Insurance Department notices 1995-09, 2014-10 and 2026-03 and that nothing that was previously deregulated from filing requirements is now required to be filed.

Southeast Zone

Louisiana

Bulletin 2026-06, dated March 31, 2026, provides guidance to any property and casualty insurer authorized to transact the business of automobile or property insurance in Louisiana regarding the requirements to notify the Commissioner when ceasing, pausing, or resuming the writing of policies in a particular region. The specific requirements provided in this Bulletin are as follows:

• An insurer authorized to transact the business of automobile or property insurance in this state shall, within ten days of providing notice to its producers or other representatives of any decision to cease, pause, or resume the writing of new insurance policies in any geographic region within the state, provide written notice of such action to the Commissioner.

• The property and casualty insurer shall include in the notice to the Commissioner, at a minimum, all of the following: (1) the effective date of the cessation, pause, or resumption; (2) the lines of insurance affected; (3) the specific geographic areas impacted; and (4) a brief description of the reasons for the action.

• To promote uniformity and ensure transparency, authorized property and casualty insurers providing notice to the Commissioner of their intention to cease, pause, or resume the writing of policies within the state, including the aforementioned requisites, are required to submit their notices through the Industry Access Portal at https://ia.ldi.state.la.us/industryaccess/ . Please be advised that the Industry Access Module titled "Market Activity Notification" will need to be added to the account by the industry access administrator in order to submit the first notice.

Bulletin 2026-04 (Revised and Reissued), dated April 29, 2026, addresses Regulation 136—Fortified Home Premium Discounts (“Regulation 136”) and NAIC Benchmark Guidance. The Louisiana Department of Insurance states that the purpose of Bulletin 2026-04 is to notify all property and casualty insurers authorized to write insurance in Louisiana of its “promulgation of Regulation 136—Fortified Homes Premium Discounts. Regulation 136 requires insurers to provide premium discounts for residential properties that obtain a FORTIFIED designation in accordance with standards developed by the Insurance Institute for Business and Home Safety (“IBHS”).” The Bulletin further provides that the discounts required under Regulation 136 shall be determined using the Louisiana-specific discount benchmark table developed by the NAIC with the applicable benchmark information at the following link: https://www.ldi.la.gov/fortifiedbenchmarks. Additionally, insurers are directed to implement the premium discounts required under Regulation 136 no later than January 1, 2027, with applicability to all new or renewed residential property insurance policies issued on or after that date.

Virginia

HB 808, effective July 1, 2026, amends § 38.2-510 “Prohibited claim settlement practices” by adding the following subsection:

D. When reducing a loss estimate of $3,000 or more, no insurer shall alter or amend an insurance adjuster's estimate of damages, photographic report data, or narrative report without (i) providing the policyholder with a detailed explanation as to why any change that has the effect of reducing the loss estimate was made; (ii) including in the report or as an addendum to the report to the policyholder a detailed list of all changes made to the report and the identity of the person who made or ordered each such change; and (iii) retaining all versions of the report and including within each such version, for each change made within such version of the report, the identity of the person that made or ordered such change.

West Virginia

For policies issued on or after January 1, 2027, SB 645 establishes payment and consumer protection standards for out-of-network ground emergency medical services including direct payment to nonparticipating providers as payment in full (subject to in-network cost-sharing limits), mandating timely claim adjudication and written denial notices, and excluding air ambulance services. Five new statutory sections, each one titled “Prohibiting surprise billing of ground emergency medical services by nonparticipating providers” set forth specific requirements.

Midwest Zone

Indiana

SB 189 enacts a new Chapter 45.2 titled “Independent Dispute Resolution” in the Indiana Insurance Code. This new chapter establishes guidelines for disputes subject to the federal independent dispute resolution process under Section 2799A-1 of the Public Health Service Act and its implementing regulations. This chapter applies to disputes involving health carriers and out-of-network providers. Health carriers are defined as entities providing health care services, benefits, or insurance plans, including insurers, health maintenance organizations, administrators, state employee health plans, and short-term insurance plans, but excludes entities providing dental or vision care services. Definitions are included for terms such as “claim specific payment information,” “facility,” “health carrier,” “independent dispute resolution,” “initiating party,” “out-of-network provider,” “provider,” and “qualified dispute.”

Iowa

HF 2232, effective July 1, 2026, creates a new Chapter 508 in the insurance code titled “Financial Exploitation of Eligible Adults” focused on preventing the financial exploitation of eligible adults. Sections within Chapter 508 set forth various definitions including “Permissible third party” which refers to an individual designated by the eligible adult or those authorized under state or federal law to receive notifications. “Qualified individual” encompasses insurance producers or individuals trained to identify and report financial exploitation. Additional sections address processes and requirements for notification to the commissioner, notification to a permissible third party, disbursements or transactions--delay, training requirements, and record retention.

South Dakota

HB 1101, effective July 1, 2026, provides that an insurer may not:

• Decline or limit coverage of an individual under any life, disability, or long-term care insurance policy solely due to the status of the individual as a living organ donor;

• Condition the continuation of a life, disability, or long-term care insurance policy on an insured individual not becoming a living organ donor; or

• Otherwise discriminate in the offering, issuance, cancellation, amount of coverage, price, or any other condition of a life, disability, or long-term care insurance policy based solely, and without any additional actuarial risk, upon the status of an individual as a living organ donor.

Wisconsin

SB 504, effective April 10, 2026, establishes requirements for “dental provider network rentals” in the newly created § 609.28 in the Wisconsin insurance code. Under this statute, “a defined network plan, preferred provider plan, limited service health organization, or other insurer that offers coverage of dental services, has a network of participating dental service providers, and engages in the practice of renting its network of participating dental service providers to other entities shall do all of the following:

• Include in any contract with a dental service provider entered into, modified, or renewed more than 30 days after the effective date of this paragraph (under § 609.28), a notification that the plan, organization, or insurer engages in the practice of network rental and a list of all current entities to which the network may be rented.

• Notify a dental service provider, electronically or in writing, that the plan, organization, or insurer has entered into an agreement with an entity under which the dental service provider's contract is rented to the entity. The notification under this paragraph shall identify the entity and be provided within 45 days of the date of the rental of the contract on which the plan, organization, or insurer enters into the agreement.”

Additionally, § 609.28 further provides that any person who obtains a network of participating dental service providers through rental from a defined network plan, preferred provider plan, limited service health organization, or other insurer shall abide by all terms and conditions of the original contract, including discounted rates or fees, between a dental service provider and the plan, organization, or insurer. Regarding termination options, a dental service provider whose contract has been rented to another entity may terminate their participation in the contract with the entity without terminating the original contract with the defined network plan, preferred provider plan, limited service health organization, or other insurer.

Western Zone

California

Bulletin 2026-2, dated March 26, 2026, addresses the prohibition on modifying formulas in rate templates and exhibits by property and casualty insurers subject to the prior approval provisions of Proposition 103. Included in this Bulletin is a general description of the information required in a complete rate application for review and approval before offering a new program or implementing any change to existing rates. The Bulletin also indicates that this process applies to rate applications filed under the Commissioner's Sustainable Insurance Strategy (SIS). Additionally, the Bulletin states that “insurers may not modify the Department's proprietary formulas in the Application, Template, Exhibits, and SIS Exhibits. Unauthorized and undisclosed modification of formulas violates the Instructions, which require insurers to submit a Filing Memorandum that sets forth "any adjustments/modifications to the data” and “any appropriate additional explanation regarding included exhibits.” The Instructions also require insurers to submit an Affidavit under penalty of perjury to certify that the information submitted in connection with a rate application is “true, complete and correct.”

Colorado

Bulletin B-5.56, issued February 10, 2026 and reissued April 6, 2026, provides “Guidance for insurers regarding annual written notice to policyholders on risk scores and mitigation discounts.” The bulletin’s stated purpose is to provide guidance to all property insurers, including the FAIR Plan, required to provide applicants upon application and policyholders annually, a plain language notice required by § 10-4-124, C.R.S. that discloses their property's wildfire risk score or classification, the insurer's wildfire risk score range, any available mitigation discounts, and appeal rights. The Division further notes that “All insurers offering property insurance policies must provide an annual written notice to policyholders and applicants, upon application, on property wildfire risk scores and mitigation discounts, and any other wildfire risk classification the insurer uses to underwrite or price a residential insurance policy including master property insurance policies for multifamily residential housing.” The bulletin includes four notification forms identified as Attachments A, B, C and D that may be used as applicable. Insurers are permitted to deviate from those forms so long as all notices include the minimum requirements in § 10-4-124(6)(a) and (b), C.R.S.

Hawaii

Senate Resolution 111 (2026) urges the Hawaii Insurance Division of the Department of Commerce and Consumer Affairs and the Hawaii Department of the Attorney General “to convene a working group to identify feasible options and mechanisms to protect the state and its residents against the effects of climate change on the availability and affordability of insurance.” Regarding such working group, this Resolution requests that the working group, with the administrative assistance of the Hawaii Insurance Division of the Department of Commerce and Consumer Affairs and the Hawaii Department of the Attorney General, “share its findings and recommendations, including any proposed legislation, with the Senate Standing Committee on Commerce and Consumer Protection and House Standing Committee on Consumer Protection and Commerce no later than twenty days prior to the convening of the Regular Session of 2027,” with a further provision that the working group be dissolved on June 30, 2027.

Nevada

Bulletin 26-001, dated March 9, 2026, explains the requirements for biomarker testing coverage in policies of health insurance. By way of background, the Division of Insurance indicated that it had received complaints from healthcare providers indicating health carriers are denying coverage for biomarker testing contrary to the requirements of the law. The purpose of this Bulletin is to explain and promote uniformity in the application of coverage requirements under Nevada law.

Oregon 

Effective April 1, 2026, the Insurance Division adopted new insurance regulations OAR 836-054-0110 to 836-054-0130 which implement HB 2563 regarding requirements for the explanation of premium increases for homeowner and personal insurance renewals. The newly adopted OAR 836-054-0120 sets forth specific insurer requirements for a premium change explanation which must identify and explain each factor that significantly contributed to the premium increase as defined in OAR 836-054-0115(3). A notice format that is permissible to use to satisfy the premium change explanation requirement is also included. Alternatively, an insurer may submit for approval a notice that provides the information required under this section in a format that aligns with other documents that the insurer uses to communicate with their policyholders. Additionally, OAR 836-054-0125 provides for periodic data reporting on a biannual basis to the Division while OAR 836-054-0130 prescribes the form and manner that a policyholder must provide to an insurer to make a request for premium increase explanation.

Utah

Effective May 6, 2026, SB 227 adds a new section to § 31A-20-101 as follows: An insurer may not consider, use, or rely upon the existence, likelihood, possibility, or exposure to punitive damages when engaging in any of the following under this title (Title 31A): underwriting; rating; risk classification; or determining premiums or other charges for a policy.

Washington

Effective January 1, 2027, HB 2428 enacts new notice provisions which focus on preventing unintentional lapses and cancellations of certain life insurance policies. The amendments apply prospectively to individual life insurance policies issued on or after the effective date and include a new section in chapter 48.23 RCW which establishes a third-party designee process for those life insurance policies. HB 2428 also amends section 48.23.030 by establishing a requirement for insurers to send a written notice of possible termination of coverage at least 30 days before the lapse of an individual life insurance policy due to nonpayment of premiums. This notice must be sent to both the policyholder at their last known address and a third party designated by the policyholder. Insurers are required to obtain and demonstrate proof of delivery for these notices, which may include methods such as first-class mail with an intelligent mail barcode, certified mail receipts, electronic read-receipts, or tracking confirmations from shipping services. The requirement does not apply to group life insurance policies, policies with premiums due monthly or more frequently, or term life insurance policies with a term of one year or less.

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Kathy Donovan is Senior Compliance Counsel, Insurance with Wolters Kluwer Financial Services. Kathy has more than two decades of experience in insurance compliance. Her expert commentary on legal and regulatory issues affecting the insurance industry is widely published, and she is a regular presenter at various industry events.