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The season of change: Insights from the NAIC Spring Meeting

How insurers can weather evolving market demands

The 2025 NAIC Spring Meeting brought industry leaders together to confront both emerging risks and regulatory transformation. From discussions on climate risk and catastrophe risk management to fresh perspectives on data governance and consumer protection, the agenda reflected the sector’s most urgent priorities. Explore the meeting’s most consequential moments, offering a clear view of what may be coming next.

Vision for a resilient insurance sector

The National Association of Insurance Commissioners (NAIC) set its agenda for the year during the 2025 spring meeting, which took place March 23–26 in Indianapolis. Under President Jon Godfread, the NAIC reaffirmed the vital role of state regulators in ensuring the strength and resilience of the US insurance sector, which generates $3.2 trillion in annual premiums. Godfread emphasized sustainable growth, preparedness, adaptability, and global leadership, urging regulators to collaborate and address challenges such as natural disasters, rising reinsurance costs, inflation, and supply chain disruptions. The meeting’s tone was set by a call to action, likening the industry’s current moment to “crunch time.”

The NAIC’s 2025 roadmap, “Securing Tomorrow: Advancing State-Based Regulation,” aims to balance market needs with consumer protection, solvency, and local considerations. Key initiatives include catastrophe resilience, expanding financial literacy, enhancing cybersecurity and consumer privacy, enforcing annuity protections, and safeguarding access to health insurance. Godfread also marked the 80th anniversary of the McCarran–Ferguson Act, which affirmed state-based insurance regulation, and encouraged regulators to have difficult conversations to ensure continued leadership and consumer protection.

The NAIC’s spring meeting focused heavily on risk-based capital (RBC), with President Godfread calling it the cornerstone of insurance regulation. The Risk-Based Capital Model Governance Task Force (RBC Mojo) held its first public meeting, launching a review aimed at ensuring capital standards reflect modern realities and risks. The initiative will develop guiding principles, conduct a gap analysis, and align related task forces. Industry groups supported the agenda, emphasizing transparency and a comprehensive approach, especially given structural shifts like increased offshore reinsurance and merger and acquisition activity. The RBC framework aims to remain effective and responsive to emerging risks.

Complementing this, the new Aggregation Method (AM) Implementation Working Group began work on the US version of the global insurance capital standard, with a multi-year plan to review regulations and finalize the AM draft by the second quarter of 2026. The NAIC also discussed a proposed asset adequacy guideline for reinsurance, aiming to improve transparency through disclosure. The first reports are expected in April 2026. Additionally, discussions began on extending RBC’s treatment of collateralized loan obligations to other structured assets.

Wildfire experiences, modeling, and potential mitigation reports were thoroughly discussed among regulators, academics, insurers, and consumer advocates during the national meeting. Collective mitigation efforts within the insurance and community ecosystems were also a significant focus. Proactive, data-driven steps states are taking, such as home fortification and disaster preparedness, were highlighted. The meeting shed light on California’s wildfire devastation, with discussions on coordination among agencies and disaster response. Insured losses in the first quarter exceeded $53 billion, with California wildfires accounting for 71% of losses. Disaster preparedness strategies included maintaining current disaster resources, issuing notices, and convening workshops. The NAIC’s strategy—coordinated by the Climate and Resiliency Task Force—includes closing coverage gaps, advocating for home hardening, using catastrophe modeling, and updating solvency tools to address climate risks.

The Property and Casualty Insurance Committee prioritized reimagining the property market data call and developing a homeowners’ insurance affordability playbook. The Climate and Resiliency Task Force explored climate risk, mitigation, and the economic impact of disasters. State regulators emphasized the importance of flood insurance, predictive data, and preparation, sharing lessons from recent disasters. The NAIC also briefed attendees on federal disaster resilience initiatives and efforts by the International Association of Insurance Supervisors (IAIS) to expand insurability and scenario analysis for climate risk.

The Big Data and Artificial Intelligence Working Group held a substantive meeting on its path forward to continue to develop regulatory tools and guidelines for insurers’ AI systems. The working group is focused on creating more oversight approaches to governance, transparency, and accountability in AI systems. It plans to provide guidance on AI program oversight, consumer disclosures, and prohibited practices. The group will also be developing AI risk evaluation tools and standardized examination tools for regulators, as well as creating new regulatory tools or guidance to help regulators review AI systems used by licensees, including AI programs implemented by insurers.

The Coalition Against Insurance Fraud (CAIF) presented at the Antifraud Task Force and said it was continuing to invest in future use of technology, including AI, machine learning, predictive modeling, automated workflow, and Generative AI. Attendees at the meeting received an update from the National Insurance Crime Bureau (NICB) regarding the mandate by most states for fraud reporting to insurance departments’ fraud bureaus. The NICB stated its commitment to modernizing and enhancing fraud reporting.

The NAIC is working to improve oversight and transparency in annuity sales, especially regarding suitability and best interest standards. Efforts include making state administrative law decisions on annuity suitability more accessible and developing a database to track how states interpret and enforce Model Law #275. The revised model law requires insurance producers to act in the consumer’s best interest and for insurers to supervise recommendations. Most states have adopted the model, with New York maintaining its own standard. The NAIC is also planning annuity suitability enforcement training at the 2025 Insurance Summit.

Actuaries discussed how best to illustrate some annuity products and the use of historical experience, as well as their communications with the parent Life Insurance and Annuities Committee and overlaps with another model regulation.

The NAIC will hold its summer national meeting in Minneapolis from August 10–13. Key topics will include natural disaster mitigation, solvency and disclosure, and enhancing the Catastrophe Modeling Center of Excellence. The organization will advance the RBC framework, holistic solvency oversight, consumer privacy, and access amid technological innovation. While a new AI oversight model may be discussed, there will be updates on the RBC framework, added disclosures, guidelines, and model laws for fair outcomes and consumer protections. Discussions will also cover state-level enforcement of annuity suitability regulations and implementation of insurance capital standards (ICS) through the AM methodology.

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