Executive summary

The U.S. insurance regulatory environment is complex and difficult to navigate, even for experienced professionals. Modern analytics can be applied to publicly available insurance product filing data to produce actionable regulatory insurance intelligence that demystifies the insurance regulatory world. A key metric, called “rate filing average days to approval,” is calculated from publicly available data and can aid filers such as insurance companies, managing general agents, and others in decision-making and formulating insurance product rollout schedules. This paper discusses rate filing average days to approval for the private passenger auto (PPA) and homeowners (HO) lines of business (LOB) in several states, how it is determined, and how it can be used to maximize resources and reduce overall time to market.

This paper has been updated from the version published on April 23, 2025. This updated version contains filings through 2025 Q2 and highlights a different list of states.

Why are rate filing average days to approval important?

When developing or revising insurance products, it is important to recognize that the natural and man-made hazards to which people and property are exposed (e.g., wildfires, hurricanes, sinkholes) differ by state, as do the laws, regulations, filing requirements, and internal Department of Insurance (DOI) rules that are not published (desk rules) with which companies need to comply to receive state regulatory approval. In addition, the unique political, legal, social, economic, and other issues in each state (e.g., potential claims fraud, affordability challenges, a recent catastrophic event) influence what each state DOI focuses on during its regulatory review. All these factors, including DOI staffing, resources, and outsourcing of reviews, contribute to regulatory review times that vary by state and LOB.

Rate filing average days to approval are estimates of the average number of days it takes for a rate filing to be approved by a state DOI once it has been submitted for review. One of the most important use cases for state approval data is to determine where and when to launch new insurance products or to facilitate multistate changes to existing products. To best utilize the rate filing average days to approval metric, a filer must first consider the goals of its product filing.

For example, if the company’s goal is to roll out a new coverage, rate change, or launch a new program as quickly as possible, it can start filing in states that have shorter approval times. This will allow the company to collect experience data and test whether the new coverage(s), changes, or products are reaching the target policyholders with the desired impact as quickly as possible. Since short approval time states are also generally smaller markets, it enables companies to make adjustments prior to rolling out to more rigorously regulated states. This approach also arms the company with experience data to improve its filing support for more rigorously regulated states, better forecast the impact, and adjust its rollout strategy before filing in more challenging states.

Alternatively, if the company’s goal is to launch a new coverage, rate change, or program across all states at approximately the same time, it may choose to prioritize filing in longer approval time states. This allows regulators in these states more time to complete their reviews while the remaining state filings are being prepared and submitted for approval. Because states with longer review times generally require more filing support, preparing additional support for the first several states can serve as a filing template to create efficiencies for future state filings. More rigorously regulated states may also require adjustments that can be incorporated before rolling out to other states. This process helps create a more consistent product across states and generates efficiencies in programming, agent training, and maintenance.

It is important that filers be aware of state-specific laws, regulations, guidelines, and other rules enforced by each DOI so that the filers can prepare filings that meet each DOI’s expectations. This preparation facilitates more efficient regulatory filing reviews by the DOIs, informs company go-to-market strategies, and aligns stakeholder expectations. Submitting filings that overlook state-specific requirements may result in more DOI questions (in the form of objections) or outright disapproval of the filing, which will extend regulatory review times and challenge the company’s overall project timelines and goals. Overlooking state requirements may also result in future fines resulting from market conduct examinations finding noncompliance with a state requirement, even after a filing has been approved.

Results of the analysis

The information presented below summarizes analytics that were created on PPA and HO rate filings specifically, although other LOB or types of filings could also be examined.

Figure 1 is a heat map of the average days to approval for PPA rate filings approved during the most recent four quarters through June 30, 2025, for a selection of states. The states with average days to approval less than the countrywide average are displayed in green, while the states with higher average days to approval are shown in orange.

Figure 2 is a heat map of the average days to approval for HO rate filings approved for the most recent four quarters through June 30, 2025, for a different set of selected states. The states with average days to approval less than the countrywide average are displayed in green, while the states with higher average days to approval are shown in orange.

Figure 3 summarizes PPA rate filing average days to approval for each selected state by calendar year in which the rate filing was approved. The current calendar year includes filings approved from January 1, 2025 through June 30, 2025. The Countrywide (CW) row includes all states across the country, including those not shown in each figure, and is used to calculate how many days each state differs from the CW average. The 4-Quarter Rolling Average column is the average for filings approved from July 1, 2024 through June 30, 2025. The last column displays each state's average review time for PPA rate filings approved in the past four quarters minus the overall average across all states.

Figure 4 summarizes average days to approval for HO rate filings for the selected states in each calendar year in which the rate filing was approved. It also calculates the difference between the state and CW average approval days in the most recent four quarters.

The averages for each approval year may be used to understand whether a state is trending toward shorter or longer review times.¹ Additionally, each state’s difference from CW in the last column may be used to indicate whether a state generally takes more time than average, illustrated by a positive value, or less time than average, illustrated by a negative value.

Conclusion

The data presented in Figures 1 through 4 can be used to estimate timelines and inform a program filing schedule for product changes or expansion into new states or LOBs. Filers can use the Difference From CW column to make decisions based on their objectives. States showing a negative value in the Difference From CW column tend to have filings approved faster, so these states could be targeted first if the company’s goal is to roll out an update as quickly as possible. States showing a positive value in the Difference From CW column tend to experience slower filing approval times and could be prioritized if the company’s goal is to launch an update across all states at the same time. Furthermore, a company could combine this data with other regulatory intelligence that Milliman offers to file in the company’s highest premium volume states first and develop a filing strategy that supports the company’s goals.

The data presented in Figures 1 through 4 can also be used to evaluate the effectiveness of different filing approval processes in states (i.e., prior approval, file and use, use and file), and/or legislative changes impacting the rate filing approval process.

Although it is possible that individual filing reviews could be longer or shorter than the historical averages, having information to optimize the order of filing submissions can be used by filers to gain efficiencies, reduce time to market, respond to market demands and evolving risk, and provide a competitive advantage. Companies can use information about filing review times to inform company stakeholders and align schedules that support a successful implementation. To license Milliman’s Regulatory Insurance Intelligence metrics and establish a filing strategy tailored to your company’s specific goals, please contact Milliman.

¹ States with a small number of filings in a particular calendar year column can have wide variations based on a single complex filing taking longer than usual or several smaller, simple filings taking less time than usual. If requested, Milliman can provide the number of filings in each LOB, state, and calendar year, and drill down on specific types of filings, such as new program filings.

² PPA filings included the following types of insurance: personal auto combinations, private passenger auto, motorcycle, recreational vehicle (RV), and other auto. Starting with the 2024 Q4 release, symbol filings and model rule filings are excluded.

³ HO filings included the following types of insurance: homeowners sub-TOI combinations, condominium, mobile homeowners, owner-occupied, tenant, and other homeowners. Starting with the 2024 Q4 release, mobile physical damage only filings and model rule filings are excluded.

⁴ Each DOI has its own way of indicating that filings are approved for use. The following are examples of disposition statuses that are considered approved in states that do not issue an “approved” disposition status: “acknowledged,” “file and use,” “filed,” “recorded effective as submitted,” “reviewed.” The information collected and the fields used to calculate average days to approval were the same across all states, regardless of whether the filing was submitted prior approval, file and use, or use and file.