This report summarizes key activities of the National Association of Insurance Commissioners (NAIC) Statutory Accounting Principles (E) Working Group (SAPWG) at its spring 2026 meeting on March 23, 2026.
SAPWG addressed a variety of topics including valuation manual implementation guidance, interest maintenance reserve (IMR), sale-leaseback accounting, separate account nonadmitted assets, long-term repos, funding agreement-backed note (FABN) disclosures, funds withheld valuation and asset-liability management (ALM) derivatives and more.
Insurance organizations should take note of these changes as they may significantly affect their accounting in 2026 and beyond.
Adopted revisions to statutory guidance
Ref #2025-34: Updates on Economic Scenario Generator and Non-Variable Annuities
Adopted revisions to SSAP No. 3, SSAP No. 51 and SSAP No. 52 provide guidance on the optional implementation period for Valuation Manual revisions related to the economic scenario generator and non-variable annuities. The revisions expand the phase-in disclosure to reflect the APF 2025-04 economic scenario generator phase-in by adding reference to VM-20 and clarify that the VM-22 (non-variable annuities) optional implementation period is reported as a change in valuation basis.
Ref #2025-23: IMR Proof of Reinvestment
Adopted concepts for an IMR proof of reinvestment developed by the IMR Ad Hoc Group. As adopted, the reinvestment template is intended to be a required component for reporting entities seeking to move into, or increase, a net negative IMR balance. The NAIC staff were also directed to continue working with the industry to refine the templates as part of the broader IMR project.


