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NAIC Statutory Accounting Principles (E) Working Group: Spring 2026 National Meeting Summary of Adopted Changes 

NAIC Statutory Accounting Principles (E) Working Group: Spring 2026 National Meeting Summary of Adopted Changes 

The NAIC Statutory Accounting Principles (E) Working Group adopted 10 items at its Spring 2026 National Meeting, covering investment accounting, leases, separate accounts, IMR, health insurance and annuity reserving. Several items are effective immediately, while others provide time for system and process updates. 

Changes Effective Immediately 

These four items are effective March 23, 2026, and must be reflected in current-period financial statements: 

Sale-Leaseback Transactions—Financing Method Required for Restricted Proceeds (Ref #2025-01 | SSAP No. 22—Leases) 

A sale-leaseback fails to qualify as a sale if the cash or assets received are restricted from use to satisfy policyholder obligations until lease repayment or subject to forfeiture if the seller terminates the contract. These transactions must use the financing method where the asset stays on the balance sheet, proceeds are recorded as a liability and payments reduce that liability over time. This applies to all contracts in effect on or after March 23, 2026 for retroactive application. Existing arrangements must meet the restriction criteria and, if not, must be reclassified immediately. 

Action Items: Review all current and planned sale-leaseback structures for restricted proceeds or forfeiture conditions. Reclassify qualifying arrangements to the financing method and assess the impact on surplus and admitted assets. 

Repurchase and Reverse Repurchase Agreements—Admittance Split (Ref #2025-28 | SSAP No. 103—Transfers and Servicing) 

Previous guidance excluded both transaction types with maturities over 365 days. The revisions split the treatment based on each type’s risk profile: 

  • Repurchase agreements (insurer is cash taker): Fully admitted long-term agreements, provided collateral of at least 95% of the transferred security’s fair value is maintained. 
  • Reverse purchase agreements (insurer is cash provider): Long-term agreements remain nonadmitted because the insurer bears the asset valuation risk. Report on Schedule BA as “Any Other Asset” and code as restricted. They stay on Schedule BA in the final year, but may be admitted if the acquired asset’s fair value is at least 102% of the original purchase price.  

Action Items: Confirm long-term repurchase agreements satisfy the 95% collateral requirement and assess the surplus impact of admitting them. Update Schedule BA coding for reverse repos and review the 102% fair value threshold at year-end for admittance eligibility in the final year. 

Removal of Superseded Shaded Text (Ref 2025-31 | SSAP Nos 40, 90 and Related Manual Sections) 

SSAP No. 40 paragraphs 11, 12 and 25 were superseded by SSAP No. 90 in 2006 but remained visible as shaded text. Those paragraphs and interpretive guidance have been formally removed. Real estate impairment accounting should reference SSAP No. 90 exclusively.  

Action Items: No accounting changes required. Update internal reference materials to confirm deletion of SSAP No. 40 paragraphs. 

Annual Statement Expense Descriptions Modernized (Ref #2025-33 | Annual Statement Blanks and Instructions—No SSA Revisions) 

Expense descriptions across all annual statement blanks have been updated to reflect current practices, removing outdated references to telegrams, cables and teletypes and replacing those to electronic formats.  

Action Items: No accounting changes. Map existing expense classifications to updated description ahead of year-end filings and update internal systems and vendor configurations. 

Changes Effective on December 31, 2026 

These items are effective for year-end 2026 reporting. System and process updates should begin as soon as possible: 

Schedule D and Schedule BA Reporting Clarifications (Ref #2025-29 | Annual Statement Blanks and Instruction) 

Three reporting elements are clarified following the first year under the principles-based bond definition: 

  • Payment Due at Maturity: Set at acquisition and note revised thereafter. Limited to non-self-liquidating Financial ABS and Non-Financial ABS on Schedule D-1-2 and “Single Entity Backed Obligations” on Schedule D-1-1. Most other Insurance Corporations Operations (ICO) categories no longer carry value in this column. 
  • Origination Balloon Payment %: Use origination-date data when available. Acquisition-date data is acceptable for secondary-market purchases where origination date is not available. 
  • Schedule BA Maturity Date: All Schedule BA investments with a stated maturity date must report it, including non-bond debt securities, surplus notes, capital notes, collateral loans and tax credit investments. 

Action Items: Review Schedule D-1-1, D-1-2 and Schedule BA data fields and processes ahead of year-end 2026. Focus on the locked payment-at-maturity column, balloon percentage sourcing for secondary-market acquisitions, and maturity date capture for all qualifying Schedule BA assets. 

Summary of Action Items 

Priority Item / Ref # Action Needed 
Immediate Sale-Leaseback (2025-01) | SSAP No. 22 Review sale-leaseback arrangements for restricted proceeds or forfeiture conditions; reclassify qualifying transactions to the financing method. 
Immediate Repo Admittance (2025-28) | SSAP No. 103 Confirm 95% collateral on long-term repurchase agreements; assess surplus impact of admitting them. Update Schedule BA for reverse repos; review 102% threshold at year-end. 
Immediate Shaded Text Deleted (2025-32) | SSAP Nos. 40, 90 Update internal manual references; confirm real estate impairment policies cite SSAP No. 90. 
Immediate Expense Categories (2025-33) | A/S Blanks Map existing classifications to modernized descriptions; update system and vendor configurations. 
Year-End 2026 Schedule D/BA Reporting (2025-29) | A/S Blanks Update payment-at-maturity column, balloon percentage sourcing, and Schedule BA maturity date capture for year-end 2026. 

Disclaimer: This advisory is provided for general informational purposes only and reflects NAIC Statutory Accounting Principles (E) Working Group adoptions as of March 23, 2026. It does not constitute accounting, legal, actuarial, regulatory or tax advice. The applicability and impact of these changes will vary based on each company’s specific facts, circumstances and lines of business. Please contact your engagement team for advice tailored to your organization’s circumstances. 

Posted In: Attest | Insurance | Insights

About the Author - Scott Esworthy, CPA

Scott is an Audit Principal and Shareholder at Brown Plus with over 30 years of experience. He specializes in the audits of property and casualty (P&C) insurance companies and employee benefit plans (EBPs). Additionally, Scott is a member of the Firm’s 401(k) Committee.

Scott co-manages one of the largest national property and casualty insurance audit practices, as ranked by AM Best. Within the Brown Plus Insurance Practice, he leads a sizable practice focused on self-insured insurance groups. Scott is highly knowledgeable in both statutory and GAAP insurance financial reporting. He is a regular speaker at the Pennsylvania Association of Mutual Insurance Companies (PAMIC) Financial Management Seminar and regularly attends PAMIC and the PICPA Insurance Conference, where he provides statutory accounting updates. He also attends Insurance Accounting and Systems Association (IASA) and National Association of Insurance Commissioners (NAIC) conferences, conventions and meetings.

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