International Updates
The International Association of Insurance Supervisors (IAIS) held its 2025 Annual Conference in Tirana, Albania, on November 13 and 14, immediately followed by a public stakeholder session of the EU-U.S. Insurance Dialogue Project. Several U.S. regulators were in attendance across both meetings, including Commissioners Mais (CT), Godfread (ND), Ommen (IA), Houdek (WI), Lara (CA), White (VA), and Pike (UT); Directors Dwyer (RI), Fox (MI), Dunning (NE), French (OH), and Gillespie (IL); and Superintendent Kane (NM).
The Annual Conference largely focused on structural shifts in the life insurance sector, national catastrophe protection gaps, global collaboration, and insurers’ societal role in supporting resilience. The EU-U.S. Insurance Dialogue Project updated stakeholders on its 2026 areas of focus and cooperation—catastrophe risk and resilience as well as innovation and technology. Key session takeaways from both meetings are detailed below.
Executive Committee Updates
New Chair Appointed: Toshiyuki Miyoshi (Vice Minister for International Affairs at the Financial Services Agency of Japan (JFSA)) was appointed the new Chair of the IAIS Executive Committee (ExCo), replacing Shigeru Ariizumi (also of the JFSA). Miyoshi served as Ariizumi’s deputy throughout Ariizumi’s tenure as IAIS ExCo Chair. Miyoshi’s appointment brings continuity not only to his IAIS role but also with other global organizations such as the G7, G20, Financial Stability Board (FSB), Basel Committee, and International Organization of Securities Commissions (IOSCO).
Miyoshi reported his top priorities as Chair would be to (1) finish work related to Insurance Capital Standard (ICS) implementation; (2) look at emerging risks related to digitalization and the impact of private credit and private finance on the insurance sector; and (3) strengthen the IAIS’ ability to analyze and assess emerging risks.
Committee Restructuring & 2026 Priorities: The IAIS adopted a revised committee structure that reflects (1) a redistribution of responsibilities; (2) new committee names to better reflect their respective objectives; (3) alignment with the IAIS’ four core objectives; and (4) new leadership (in most cases).
The Monitoring and Risk Assessment Committee (MRC), formerly the Macroprudential Committee, will essentially operate as the Macroprudential Committee did, overseeing the monitoring of key insurance sector risks and trends and proposing appropriate responses. It will continue to be chaired by Dieter Hendrickx (National Bank of Belgium). The committee’s 2026 priorities include work related to the Global Monitoring Exercise (GME), development of the mid- and end-of-year Global Insurance Market Report (GIMAR), and continued reporting to the FSB.
The Standards and Supervisory Practices Committee (SSC) will assume all responsibilities of the former Policy Development Committee and some responsibilities of the former Implementation and Assessment Committee. It will set and maintain supervisory standards and support member implementation of those standards, including by sharing good practices and developing guidance. The SSC will be co-chaired by Judy French (Ohio) and Farzana Badat (South Africa). This is the first time an IAIS committee will have two leaders, which is intended to demonstrate the IAIS’ commitment to its diverse membership and enhance engagement with Emerging Market and Developing Economy (EMDE) jurisdictions. The SSC Co-Chairs identified the following areas of focus in 2026:
- Potential development of supervisory guidance, likely in the form of a draft Application Paper, to address alternative assets and asset-intensive reinsurance (AIR)—this is in response to the Issues Paper on the same topic
- Recovery and resolution-related guidance
- Working with the IAIS Secretariat to strengthen capacity building efforts
The Implementation Assessment Committee (IAC), formerly the Implementation and Assessment Committee, will focus exclusively on assessing the implementation of IAIS standards. It will be chaired by Vicky White (Prudential Regulation Authority (PRA), UK). In 2026, the IAC’s work will be dominated by the start of implementation assessments for the ICS and elements of ComFrame within Insurance Core Principles (ICPs) 7 (Corporate Governance), 8 (Risk Management and Internal Controls), 9 (Supervisory Review and Reporting), 16 (Enterprise Risk Management for Solvency Purposes), 23 (Groupwide Supervision), and 25 (Supervisory Cooperation and Coordination).
Holistic Framework Updates: The FSB, as part of the three-year review cycle, is reviewing the GME methodology and overall effectiveness of the Holistic Framework. The results of the review are expected soon. The recent Targeted Jurisdictional Assessments (TJAs), focused on six additional jurisdictions, revealed significant progress in many areas but found gaps in resolution planning and liquidity risk management.
Reports on the Horizon: The final Issues Paper on Structural Shifts in the Life Insurance Sector was published this week (see below), the GIMAR will be published on December 1, and draft revisions to the Application Papers on recovery and resolution planning will be published for a 90-day consultation in the coming weeks.
Structural Shifts in the Life Insurance Sector
The Annual Conference featured a dedicated panel to discuss life insurance “structural shifts”—insurers’ increased investment in alternative assets and the growth of cross-border AIR—as well as a roundtable session on private credit investment, which is a key sector-wide theme identified in the 2025 GME. Panelists included Commissioner Ommen (IA); Vicky White (PRA); and representatives from the Bank for International Settlements (BIS), the Global Federation of Insurance Associations (GFIA), and Global Atlantic. The roundtable was led by Gareth Truran (PRA), but several regulators facilitated small-group discussions.
Issues Paper: As noted above, the final Issues Paper on Structural Shifts in the Life Insurance Sector was released this week (a report on the Paper will appear in a future issue of the NOLHGA Wire). Panel and hallway discussions indicate that the final paper is expected to be more balanced than the draft, which received more than 530 comments. The final paper will reportedly acknowledge the sufficiency of the ICPs in addressing perceived risks. However, enhanced supervisory guidance may be needed around valuation, liquidity, and other concerns, likely in the form of draft application papers (as previewed by the SSC Chairs).
Alternative Assets Discussion
- Vicky White provided the UK’s view on insurers’ investment in alternative assets, noting that the PRA has taken steps to better position it to respond to risks, but she does not have an objection to private/alternative assets.
- Commissioner Ommen remarked that the shift in insurer practices is not new and has occurred under close regulatory scrutiny for several years. When discussing risks, Ommen said an important part of risk management is regulatory capability—there is a layer of complexity that requires specialized resources and informed supervisors. He also noted that the definition of alternative assets can be a challenge for regulators because of the uniqueness in insurer strategies.
- The BIS raised systemic risk concerns specific to private equity–linked insurers and their interconnectedness with the broader financial system, particularly due to their “significantly high allocation to structured products and affiliated assets.” Earlier in the discussion, Commissioner Ommen referenced the NAIC’s early work on the 13 Considerations, where there was clear recognition that ownership structure is not necessarily the concerning issue and can serve to mitigate risks in certain cases.
- Industry representatives emphasized the need to have more balanced discussions that consider the liability side of the balance sheet, which is often unaddressed but is critically important to the conversation.
- During the private credit roundtable, a few supervisors acknowledged that there is a difference between large, sophisticated insurers and smaller insurers that are “chasing yield” without the appropriate sophistication or resources, which is an area of concern.
- Speakers during both the panel and roundtable expressed a desire to move away from the “alternative” assets terminology, given the wide range of assets that can be considered alternative or private, and instead focus on risks.
- Panelists agreed that capital is needed to address the growing retirement services protection gap, and that AIR is a valuable mechanism to attract and free up capital.
- Vicky White acknowledged the small AIR market in the UK, adding that AIR’s increased growth and complexity could lead to “rapid buildup of risks in the UK market.” To prepare for that growth, White said the PRA has been adjusting to ensure its regulatory framework is sufficient.
- Industry representatives spoke to the robust governance and risk management practices in place to ensure risks are appropriately managed and specifically noted the importance of ceding to offshore jurisdictions with rigorous regulatory regimes. Commissioner Ommen agreed and emphasized the need for strong relationships between jurisdictions and a mutual understanding of each other’s regulatory frameworks.
- To address AIR-related risks, the BIS suggested enhanced transparency and disclosures, alignment of regulatory frameworks, and increased supervisory attention on liquidity risk.
The EU-U.S. Insurance Dialogue Project, comprising representatives from the NAIC, Federal Insurance Office (FIO), Federal Reserve, European Insurance and Occupational Pensions Authority (EIOPA), and the European Commission, held its first public stakeholder session since 2023. The session was moderated by Petra Hielkema (Chair, EIOPA) and featured remarks from Commissioners Ommen, Houdek, and Lara. The purpose of the session was to update attendees on past and upcoming workstream activities.
The Insurance Dialogue Project revised its workstreams for 2026-2027. The Innovation and Technology Workstream will build on its work from prior years on Artificial Intelligence and Machine Learning but will focus more on generative AI developments and emerging use cases. The workstream also intends to discuss cyber risk/insurance issues and examine ways supervisory technology (SupTech) can be used to improve financial and market conduct oversight and compliance.
In other international news, on November 13, the International Forum of Insurance Guarantee Schemes (IFIGS) met with representatives of the IAIS ExCo to discuss the protection gap for policyholders not covered by an insurance guarantee scheme (IGS). IFIGS was represented by Canada (PACCIC), Kenya, Romania, Isle of Man, and the United States (representatives from Faegre Drinker). The IAIS representatives included Conor Donaldson, Hanne van Voorden, Ayana Ishii (IAIS Secretariat), Siham Ramli (IAIS ExCo Vice-Chair, Morocco), and Jesus Cisneros (EIOPA, on behalf of ExCo Vice Chair Petra Hielkema).
IFIGS requested that the IAIS acknowledge as a best practice that a jurisdiction must have an IGS to prevent a policyholder protection gap, highlighting the diversity of IGS arrangements available to meet jurisdictional differences. The IAIS said it could not go that far but invited further dialogue on IGS matters and policyholder protection. In particular, IAIS representatives requested additional detailed information about specific examples of IGS involvement and policyholder outcomes.
The Secretariat further focused on the forthcoming work of the IAIS Resolution Working Group—updated application papers on recovery planning and resolution planning will be published for consultation in the next few weeks for a three-month comment period. IFIGS also highlighted the successful tabletop exercises that NOLHGA and the NCIGF facilitated for U.S. regulators and encouraged supervisors to ask their U.S. colleagues about that experience.
Staff Contact - Sean McKennaNAIC Updates
The Life RBC Working Group discussed two material workstreams during its call on November 14, 2025: Highlights included:
- Discussion of Academy’s Covariance Deck: The working group heard comments from several stakeholders on the deck outlining the American Academy of Actuaries’ recommendations related to correlation in the life RBC formula. Industry raised several concerns regarding timing in light of ongoing RBC workstreams (Generator of Economic Scenarios (GOES) implementation, in particular) and the material effect the changes could have on individual companies. Several commenters also noted that any review of covariance will need to include an analysis of the base factors. On timing, Philip Barlow (DC-Chair) emphasized that no changes would be implemented before regulators fully understood the impact of GOES, but he added that he does not want the work to stall in the meantime. He recognized the validity of industry’s technical points on the Academy’s recommendations. This work will continue into next year.
- Exposure of Collateral Loans (Conceptual) Proposal: The working group also exposed a proposal related to the RBC/Asset Valuation Reserve (AVR) treatment of collateral loans in light of recent reporting changes (see Attachment 9 of the Meeting Materials). Earlier this year, the NAIC adopted changes that allow look-through treatment for collateral loans backed by mortgages, but this was always designed to be a temporary solution until regulators developed a permanent approach. The proposal suggests extending this look-through approach to collateral loans backed by other collateral types (e.g., JVs/LPs/LLCs, residual tranches, etc.). Kevin Clark (IA) expressed a desire for these changes to be implemented by year-end 2026 reporting. This item was exposed for 60 days.
The Life Actuarial Task Force (LATF) adopted changes to Actuarial Guideline (AG) 49-A (the Application of the Life Illustrations Model Regulation to Policies with Indexed-Based Interest) related to the use of certain indices in illustrations. As of the last exposure period, the task force bracketed the timeframe an index must be in existence before historical returns could be shown in an illustration. The task force ultimately decided to select 10 years (instead of five), in part to align with the timeframe included in the Annuity Disclosure Model Regulation.
The task force also exposed APF 2023-10, which had been delayed while the NAIC finalized the new Generator of Economic Scenarios (GOES). The exposure would modify the discount rate for the VM-20 Stochastic Reserve. The item proposes using the Net Asset Earned Rate on additional reserves as the discount rate while also allowing the Direct Iteration Method as an alternative approach to calculating these scenario reserves. Regulators raised questions about double counting and how the dollar impact of the change would be disclosed. Comments are due January 21.
On November 14, the NAIC released its 2025 Report on the Cybersecurity Insurance Market. Highlights included:
- Market Dynamics: For the first time, the U.S. cyber insurance market saw a reduction in direct written premium, with $9.14 billion written in 2024—a 7% decrease from the previous year. Globally, premiums reached nearly $15 billion, reflecting continued growth outside the United States.
- Claims & Coverage: The frequency of cyber claims rose nearly 40% in 2024, while average ransom payments dropped by 77%, indicating improved controls and negotiation. The report details changes in policy structures, with a new three-way split (primary, excess, and endorsement) providing greater transparency.
- Threat Landscape: Ransomware, business email compromise, and credential abuse remain top concerns. The report analyzes the impact of AI-driven social engineering, supply chain risks, and the human element in cyber incidents.
- Market Innovation: The report explores the evolving role of reinsurance, vendor-backed cyber warranties, parametric covers, and capital market instruments such as catastrophe bonds in expanding market capacity and resilience.
- State-Level Insights: For the first time, state-level data is included, revealing significant geographic concentration of premiums and adoption trends.
Privacy Updates
A Pennsylvania federal judge has suggested she may toss a proposed action alleging that The Cigna Group failed to safeguard private health data by tracking health plan members’ website usage. The case alleges that Cigna’s use of website cookies to capture members’ visit information and allowing such information to be seen by programs from technology companies violates the Pennsylvania Wiretapping and Electronic Surveillance Control Act and HIPAA. However, Judge Beetlestone issued an Order to Show Cause, demanding a brief explaining why the suit shouldn’t be dismissed for lack of standing and explaining that the current briefing is inadequate to show how plaintiffs suffered an “injury in fact.”
Attorneys General from California, Connecticut, and New York announced that they secured a $5.1 million settlement from educational technology company Illuminate Education, Inc., for failing to protect student information, including certain medical information. The settlement stems from a December 2021 data breach where a hacker obtained access by using a former employee’s credentials. In addition to the settlement payment, Illuminate has agreed to, among other items, (1) implement appropriate access control and account management, including terminating the credentials of former employees and conducting audits to check that all valid credentials belong only to current employees; (2) implement appropriate real-time monitoring and alerts for suspicious access and activity; and (3) implement appropriate real-time safeguards to protect backup databases, such as not storing backup databases within the same network segment as original databases.
CalPrivacy has revealed three legislative initiatives for the 2026 session that it plans to either back or formally sponsor. One of the main proposals seeks to introduce robust protections for whistleblowers under California’s technology and privacy regulations. This would include establishing a reward system to motivate whistleblowers, creating a special designation that allows the Enforcement Division to partner with whistleblower attorneys on particular cases, permitting whistleblowers to receive a portion of administrative penalties, and enacting anti-retaliation rules to promote participation and safeguard those who come forward. Other suggested measures involve broadening the right to deletion to include consumer data obtained from third-party sources, not just data collected directly from individuals. Additionally, businesses would be required to offer more options for submitting privacy requests, such as providing an online form in addition to the standard email method.
CalPrivacy announced that the California Office of Administrative Law has approved regulations to further implement the Delete Act. The regulations will be effective January 1, 2026, and describe how Californians can submit a delete request through California’s Delete Request and Opt-Out Platform (DROP) and how data brokers must retrieve and process the requests. Pursuant to the regulations, starting August 1, 2026, data brokers must (1) access DROP at least every 45 days to retrieve and process consumer deletion requests and (2) report the status of each deletion request in DROP within 45 days of retrieving it. Data brokers must also maintain a list of all deletion requests to ensure that consumer personal information remains deleted.
Staff Contact - Sean McKenna