Zoning In - Winter 2026

Northeast Zone

Delaware

Domestic/Foreign Bulletin 151 (Revised) with a Reissued date of December 1, 2025, addresses the mandatory compliance applicable to the reporting of geographic allocation of premiums under 18 Del. C. § 705 (payments to fire companies). In this bulletin, the Department of Insurance reminds all carriers that compliance with reporting of geographic allocation requirements under 18 Del. C. § 705 is mandatory and that these requirements have been outlined in prior bulletins. Regarding possible issues with carrier filings that may lead to the misallocation of premium tax payments, the Department indicated that “carriers are expected to take immediate action to ensure internal processes fully support full compliance with Section 705. Accurate reporting is not only a statutory obligation, but it is also critical to maintaining the integrity of Delaware’s premium tax system and ensuring that Delaware’s fire departments and companies receive the funding they are entitled to.” Bulletin 151 (Revised) provides additional information on the Geographic Information System (“GIS”) requirement and the allocation of premiums, as well as a summary of HB 371 legislative changes. HB 371 amended 18 Del C. § 705 with adjustments concerning how distributions from taxes collected by the Insurance Commissioner are allocated to fire companies and departments throughout Delaware.

Maryland

Bulletin 26-3, dated January 21, 2026, informs all insurers conducting business in Maryland about the process to submit notifications to the Administration when a producer’s appointment is terminated “for cause.” This bulletin further states that “Section 10-118(e)(1)(ii) of the Insurance Article, Annotated Code of Maryland (2017 Repl. Vol.), requires an insurer or an authorized representative of an insurer to notify the Commissioner of the termination of a producer’s appointment with the insurer when the termination, in whole or in part, is a result of the belief that the producer has engaged or is engaging in any of the activities set forth in §10-126 of the Insurance Article.” The Maryland Insurance Administration details the two available methods for insurers to use to make the required notification to the Commissioner: an online form and an email method.

New Jersey

AB 1203 (2024), cited as the “Pet Insurance Act” (Act) was approved as P.L. 2025, c.224 on January 16, 2026. Similar to NAIC’s Pet Insurance Model Act (Model 633), New Jersey’s Act provides detailed definitions applicable to pet insurance and establishes provisions including those for applicability, producer training, required summary descriptions, benefits schedules, policy renewals, waiting periods, conditions, wellness programs, effective dates, free look period, and disclosures. Regarding consumer disclosures under AB 1203, those required disclosures include whether the policy excludes coverage due to a preexisting condition, a hereditary disorder, a congenital anomaly or disorder, or a chronic condition. Also, if the policy includes any other exclusions, the following statement must be included in the policy: “Other exclusions may apply. Please refer to the exclusions section of the policy for more information.” Additional consumer disclosures include:

• Whether any policy provision that limits coverage through a waiting or affiliation period, a deductible, coinsurance, or an annual or lifetime policy limit.

• Whether the pet insurer reduces coverage or increases premiums based on the insured’s claim history, the age of the covered pet or a change in the geographic location of the insured.

• If the underwriting company differs from the brand name used to market and sell the product.

AB 1203 specifies that this Act shall take effect on “the first day of the 12th month next following the date of enactment.”

Pennsylvania

Notice 2026-03 dated January 17, 2026, states that the following types and kinds of commercial property and casualty insurance have been deregulated from rate filing requirements: Fidelity and Surety. The notice further states that “Notwithstanding the deregulation of the rates specified, all the rates must continue to comply with applicable Commonwealth law including, but not limited to, the Unfair Insurance Practices Act (40 P.S. §§ 1171.1—1171.15) regarding prohibiting unfair methods of competition and unfair or deceptive acts or practices. Insurers are also reminded that rates may not be excessive, inadequate, or unfairly discriminatory under Commonwealth law (see 40 P.S. § 1183(d)). Nothing in this notice alters or supersedes the requirements of other applicable Commonwealth law.” This deregulation is effective January 17, 2026.

Southeast Zone

Georgia

Chapter 120-2-113 of the Office of Commissioner of Insurance rules, titled “Reduction in Prior Authorization Requirements Program” became effective on December 23, 2025. Included in this new Chapter is Section 120-2-113-.04 establishing reporting requirements. Specifically, “by July 1, 2026, and annually thereafter on or before January 1 of each calendar year, each insurer that utilizes prior authorization requirements shall submit to the Commissioner a filing concerning their respective program. Such filing shall include:

• A full narrative description of the program

• The criteria for participation in the program

• A list of the procedures and services subject to the program

• The number of healthcare providers participating in the program.”

Louisiana

Bulletin 2026-02, dated January 8, 2026, provides clarification on the first annual reporting period in accordance with La. R.S. 22:1482.2 as it relates to Regulation 138 - Premium Discount for Dashboard Cameras with Telematic Systems: Commercial Motor Vehicles. A Notice of Intent to Promulgate Regulation 138 – Premium Discount for Dashboard Cameras with Telematic Systems: Commercial Motor Vehicles was filed on December 10, 2025. Under La. R.S. 22:1482.2(F)(1), “each admitted insurer authorized to issue commercial motor vehicle insurance in this state shall submit an annual report to the Commissioner by March first of each year, detailing all of the following: (a) the number of commercial motor vehicles receiving the discount; (b) the aggregate savings provided to policyholders; and (c) any observed changes in claim frequency or severity attributable to dashboard cameras and telematics usage.” Each admitted insurer authorized to issue commercial motor vehicle insurance is required to submit their first annual report on March 1, 2027.

Puerto Rico

Circular Letter CC-2026-2053-D, dated January 14, 2026, addresses Law No. 10-2026 which aims to strengthen public policy to promote smoking cessation and prevent initiation of smoking. The Circular Letter states that “Law No. 10-2026 amended Article 3 of Law No. 21-2008, known as the “Protocol for the Treatment of Tobacco Use and Dependence Act” to require insurers, health insurance organizations, health plans, and any entity that provides health services by contract to provide annually to the Division of Prevention, Tobacco Control, and Oral Health, attached to the Department of Health of Puerto Rico, the information concerning their medical coverage for the provision of services as required in this Article. This information must also include details on the medications available to their subscribers who require treatment for tobacco use and dependence.”

Midwest Zone

Illinois

Company Bulletin 2025-23, dated December 31, 2025, provides guidance to health insurance issuers subject to Section 55 of the Network Adequacy and Transparency Act (“NATA”) and addresses the requirement to implement the Uniform Electronic Provider Directory Information Forms (the Uniform Directory Template). Specifically, health insurance issuers “must make the Uniform Directory Template available to onboarding, current, and terminating providers so that preferred providers can ensure their information is accurate and up to date with the issuer and to ensure consumers have access to correct provider directory information.” The bulletin further provides that “beginning July 1, 2026, all providers must use the Uniform Directory Template to notify issuers of their provider directory information as required by 215 ILCS 124/25 and 42 U.S.C. § 300gg-139.” Instructions on the form’s use are included in the Uniform Directory Template. Provider directories verification requirements in 215 ILCS 124/25(a)(3) and 215 ILCS 124/35 are also referenced in this bulletin. Issuers are required to verify their provider directories for accuracy at least every 90 days and providers must verify the accuracy of their information at least every 90 days under 215 ILCS 124/35.

Michigan

Bulletin 2026-01-INS, dated January 5, 2026, provides information on the Department of Insurance and Financial Services’ (“DIFS”) updated versions of its Utilization Review forms (“UR Forms”). The following list details the forms that are used to facilitate appeals of UR determinations under Michigan law:

• Application for Unconditional Certification of Auto Insurance Utilization Review Program (“FIS 2362”)

• Auto Insurance Utilization Review Provider Appeal Request (“FIS 2356”)

• Auto Insurance Utilization Review Insurer Reply to Provider Appeal (“FIS 2361”)

• Auto Insurance Utilization Review Insurer Annual Report (“FIS 2358”)

• Auto Insurance Utilization Review Provider Attestation (“FIS 2376”)

The DIFS includes a link to the online versions of these forms in this bulletin and further states that as of February 15, 2026, it will no longer accept outdated UR Forms.

Missouri

Insurance Bulletin 26-02, issued January 27, 2026, addresses the requirement for insurers to update their “Catastrophe/Disaster Coordination Contact.” The Department requests that each insurer insuring real or personal property in the state provide current Catastrophe/Disaster Coordination Contact information. The bulletin provides information concerning the type of communications that such “Contact” is expected to be able to provide. The bulletin also indicates that if the Catastrophe/Disaster Coordination Contact has changed from what was previously provided, insurers are requested to submit updated contact information. As indicated in prior bulletins for this “Contact” information, the Department requests that the information be updated using the Uniform Certificate of Authority Application (“UCAA”) process by completing Form 14. The Department further requests that no duplicate filing be submitted if the Catastrophe/Disaster Coordination Contact has not changed.

Western Zone

California

Bulletin 2026-01, dated January 9, 2026, addresses the “Mandatory Moratorium on Cancellations and Non-Renewals of Policies of Residential Property Insurance After the Declaration of a State of Emergency.” As enacted by Senate Bill 824 (Lara, Chapter 616, Statutes of 2018) Insurance Code Section 675.1, subdivision (b)(1) provides: “An insurer shall not cancel or refuse to renew a policy of residential property insurance for a property located in any ZIP Code within or adjacent to the fire perimeter, for one year after the declaration of a state of emergency as defined in Section 8558 of the Government Code, based solely on the fact that the insured structure is located in an area in which a wildfire has occurred. This prohibition applies to all policies of residential property insurance in effect at the time of the declared emergency.”

This bulletin further defines a “policy of residential property insurance” and provides information on specific prohibited cancellation and non-renewal actions, as well as the applicable ZIP codes. Additionally, the Department of Insurance states that “all admitted and non-admitted insurers writing policies of residential property insurance in California must offer to rescind any notices of cancellation or non-renewal issued due to wildfire risk since the Governor’s December 23, 2025 emergency declaration, and offer to reinstate or renew policies in effect at the time of the applicable emergency declaration, if any such notices of cancellation or nonrenewal were issued due to wildfire risk on or after the date of the emergency declaration, and the properties are located in ZIP Codes identified by this bulletin.”

Montana

Advisory Memorandum of January 14, 2026 provides Guidance for the Montana Pet Insurance Act that was effective on October 1, 2025, in accordance with 2025 House Bill 78. Regarding the sale of pet wellness programs that are not insurance, the “Commissioner desires to clarify that the language in Section 6(i)(b) does not prevent insurers and producers from addressing or discussing wellness programs at any time, provided Section 6(2) (a-f) is adhered to, including during the sale, solicitation, and negotiation of insurance, for non-marketing reasons including, but not limited to, the following:

• Responding to questions from consumers

• Informing consumers as to the existence of a wellness product

• Educating consumers as to the differences between a wellness product and an insurance product

• Informing consumers as to resources to learn more about a wellness product.”

Additionally, the Advisory Memorandum provides guidance for the required free look period including disclosures, minimum standard, and provisions for premium refunds.

Nevada

Bulletin 25-006, dated December 22, 2025, addresses unfair trade practices in the sale of Medicare supplement policies and advises insurers that the Division will be monitoring the market to ensure compliance with the mandate under Senate Bill 292 enacted in 2025. SB 292 requires insurers that offer Medicare supplemental policies in Nevada “to allow individuals who are under 65 years of age and eligible for and enrolled in Medicare on the basis of disability or end-stage renal disease to purchase any Medicare supplemental policy that the insurer offers to new insureds who are 65 years of age or older. These products must be offered to such eligible and enrolled Medicare members regardless of age, and insurers are prohibited from imposing any limitation that does not also apply to any other person who is 65 years of age or older.”

New Mexico

In a Notice dated December 8, 2025, the Office of Superintendent of Insurance (“OSI”) reminds insurers, adjusters, producers, and insurance professionals conducting business within New Mexico of the mandatory reporting requirements under the New Mexico Insurance Fraud Act. Specifically, “under Section 59A-16C-6(A), every insurer or licensed insurance professional who has a reasonable belief that an act of insurance fraud will be, is being, or has been committed must furnish and disclose all relevant knowledge and information to OSI’s Insurance Fraud & Law Enforcement Division (“IFLED”). Additionally, all insurers and licensees are required to fully cooperate with any investigation conducted by IFLED regarding suspected or confirmed insurance fraud activity.”

Oregon 

The Memorandum of December 9, 2025, issued by the Oregon Division of Financial Regulation, provides key updates for insurers related to financial responsibility requirements under SB 840. These provisions became effective January 1, 2026, as SB 840 amended Oregon’s financial responsibility and suspension laws related to uninsured driving and accidents. Updates included a shortened SR-22 filing requirement for driving uninsured convictions and the repeal of mandatory suspension for uninsured accidents.

Regarding the required “Statement from Insurer” this Memorandum notes that “for accidents occurring on or after January 1, 2026, the Department of Motor Vehicles (“DMV”) will not change their uninsured accident determination following an insurer’s denial of coverage unless the driver provides proof of coverage in the form of a statement — on insurance company letterhead and signed by an authorized employee of the insurer — indicating that the driver was insured at the time of the accident.” This Memorandum further states that:

• Insurers may want to inform their customers about the shortened SR-22 requirement and the repeal of mandatory uninsured accident suspensions.

• Insurers should be prepared to provide a signed statement on company letterhead for the DMV if asked by a customer.

• Insurers may need to modify internal systems and workflows to reflect these changes.

Wyoming

The Wyoming Insurance Department’s Rules & Regulations Chapter 73 titled “Provider Exemptions for Prior Authorization” became effective December 3, 2025. This new Chapter, comprised of Sections 1 through 10, establishes “standardized procedures for health insurers and utilization review entities to streamline prior authorization processes, clarify provider exemptions, appeals, and disclosures, and ensure compliance across disability and health insurance operations.” In addition to enacting authority and definitions provisions, the rules in Chapter 73 also set forth the following specific requirements:

• Applicability: This regulation shall not apply to healthcare providers who have not entered into a written agreement with a health insurer or contracted utilization review entity as provided in W.S. § 26-22-503. Out of state providers are ineligible to receive provider exemptions.

• Initial exemption: Health insurers or contracted utilization review entities must establish procedures to verify healthcare providers’ initial exemptions from prior authorization requirements by March 31, 2026. These procedures must be accessible to the Commissioner upon request.

• Appeals: Health insurers or contracted utilization review entities are required to implement an appeal process for cases where healthcare services are denied due to the absence of a provider exemption from prior authorization requirements or a lack of prior authorization. This appeal process must be included in all insurance policies and contract forms subject to W.S. Section 26-15-110.

• Exemption review: Health insurers or contracted utilization review entities may review healthcare providers’ exemption statuses every 12 months. Providers must comply with these reviews, and failure to do so may result in the revocation of the exemption.

• Verification of exemption: Healthcare providers must receive confirmation from health insurers or contracted utilization review entities that they are exempt from prior authorization requirements before performing healthcare services when prior authorization is required. This confirmation is pursuant to W.S. Section 26-55-112(h).

• Policy disclosure regarding provider exemptions from prior authorization requirements: Disability policies delivered or issued for delivery in Wyoming on or after January 1, 2026, must include a notice within the policy or contract form stating whether W.S. Section 26-55-112 applies.

• Prior authorization requests in addition to exemptions: The regulation specifies that healthcare providers may still obtain prior authorization from health insurers or contracted utilization review entities even if exemptions exist, as nothing in W.S. Section 26-55-112 or this regulation prevents such requests.

• Payment of claim under medical necessity standard: Any adverse determination based on medical necessity, as defined by W.S. Section 26-40-102(a)(iii), resulting from prior authorization or claim processing errors, will be subject to internal and external review procedures described in W.S. Section 26-40-201.

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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.