Article
Updates from the Statutory Accounting Principles Working Group’s December 2025 fall national meeting
Dec. 17, 2025 · Authored by Daniel E. Buttke, Josh Leinum
This report summarizes key activities of the National Association of Insurance Commissioners (NAIC) Statutory Accounting Principles (E) Working Group (SAPWG) at the fall 2025 national meeting on Dec. 9, 2025.
SAPWG discussed a variety of topics including sale-leaseback accounting, equity method investments, interest maintenance reserve (IMR) and more. Insurance organizations should take note of these changes as they may significantly affect their accounting in 2025 and beyond.
Adopted revisions to statutory guidance
Adopted revisions support removal of the investment subsidiary concept from statutory reporting, as both regulators and NAIC staff noted that the current reporting of “investment subsidiaries” lacks transparency and allows companies to self-calculate the risk-based capital (RBC) treatment simply by placing the investment in an investment subsidiary rather than directly holding the investment. This adoption action is effective Dec. 31, 2026, and includes sponsoring a blanks proposal to remove annual statement reporting components as well as a referral to the Capital Adequacy (E) Task Force to eliminate RBC-related instructions.
Adopted revisions to the preamble clarify treatment of issue papers in level 5. The revisions also reference U.S. Securities and Exchange Commission (SEC) rules and interpretations as sources of authoritative U.S. Generally Accepted Accounting Principles (GAAP) for SEC registrants and are effective upon adoption.
Adopted new Standard Accounting Principles (SAP) concept revisions allow residential mortgage loans held in qualifying statutory trusts to be captured in scope of SSAP No. 37. These revisions are effective Jan. 1, 2027, with early adoption permitted.
Adopted, with modification, certain revisions from Accounting Standards Update (ASU) 2019-12, Simplifying the Accounting for Income Taxes, which was intended to reduce complexity in income tax accounting standards. The revisions also incorporate U.S. GAAP guidance from APB Opinion No. 28, which had previously been incorporated by reference. This adoption is effective for year-end 2025 reporting.
Adopted revisions, effective Dec. 31, 2026, incorporate a new reporting column to identify private placement securities in relevant investment schedules and an aggregate disclosure that details key investment information by type of public or private security.
Adopted revisions, effective Dec. 31, 2026, clarify the existing disclosure financial statement note location and frequency for debt security disclosures and incorporate disclosures for residuals that identify the company’s measurement method, whether the company is transitioning from the practical expedient to the allowable earned yield (AEY) method, and for those following the AEY method, information comparable to SSAP No. 43 for impaired securities.
Adopted revisions to SSAP No. 92 and SSAP No. 102 clarify that retirement plan assets can be held at net asset value (NAV) and shall be included in the required fair value disclosure. This adoption is effective for year-end 2025 reporting.
