SERFF Modernization: The Wrong Kind of Modern
- Written By Tim Perr
SERFF is essential infrastructure for the insurance industry. It connects insurers and state regulators for the filing and review of rates, rules, and forms. That function is indispensable. The technology strategy behind SERFF Modernization, however, deserves much harder scrutiny.
How SERFF Modernization Landed on Low-Code
When the modernization effort began roughly six years ago, the NAIC engaged PwC to help evaluate technologies, conduct the modernization pilot, and develop the roadmap and blueprint for the new SERFF. That process ultimately centered the modernization effort around Appian and its low-code platform.
The low-code promise was compelling: applications could be built faster, modified more easily, and maintained with less dependence on traditional software development. At the time, that may have seemed reasonable. Even at Perr&Knight, we considered low-code as the core of the technology stack for what is now known as PK1Cloud. In hindsight, we are quite happy that our internal technology team rejected that option.
The problem is that technology moves extraordinarily fast.
Technology Moves Faster Than Any Roadmap
Software development today has been transformed by AI-assisted coding, cloud-native platforms, agentic systems, and technologies that were largely nonexistent when the SERFF modernization architecture was conceived. And as a warning to all of us, six years from now many of today’s cutting-edge development tools will undoubtedly look dated too.
And that is exactly the point. In our opinion, SERFF never needed to predict the future of software. The better architecture would have been to make SERFF as technology-agnostic as possible by focusing first on an extremely robust, comprehensive, two-way API.
What SERFF Needed: An API-First Architecture
SERFF itself could then have focused on what only SERFF can do: provide the secure regulatory transaction layer that receives everything an insurer needs to submit, returns everything a regulator communicates, maintains the official regulatory record, and exposes the entire process through modern APIs.
Let the market build the applications.
With fully functional APIs, insurers could build their own filing environments. Technology companies could create and license specialized tools and automation. Consulting firms could integrate regulatory filing into broader product development and compliance platforms. And as technology evolved, those API-connected front ends could evolve with it without requiring the NAIC to repeatedly reinvent SERFF.
The SERFF Modernization API Gap
Ironically, the NAIC’s original modernization materials recognized the importance of APIs and third-party integration. Yet the modernized system is now moving toward implementation without critical API capabilities that outside platforms need to dynamically and completely pull information from and push information to SERFF. It has recently been announced that these API capabilities will not be available in the modernized version until at least the first quarter of 2027, even though the first state is scheduled to move to the new system later this month. The NAIC says these APIs are simply not a priority to them.
Meanwhile, SERFF Modernization has taken years longer than originally expected, costs have exceeded initial forecasts, functionality has been delayed or deferred, and the industry faces a transition period in which users may be required to operate across both legacy and modernized SERFF environments.
The criticism here is not that PwC or the NAIC should have predicted artificial intelligence or its impact on technology six years ago. No consultant could reasonably have done that. The architectural mistake was building around a particular vision of how applications would be developed rather than building infrastructure that would remain useful regardless of how applications were developed.
How PK1Cloud Works Alongside SERFF
At Perr&Knight, that distinction is central to how we are building PK1Cloud. Our objective is not simply to create a nicer interface for SERFF. PK1Cloud is designed to manage insurance product development, forms, rates, filing preparation, regulatory correspondence, objections, approvals, and compliance workflows within one environment while interacting with SERFF behind the scenes.
We believe insurers should spend their time developing and managing insurance products, not navigating regulatory software user interfaces. So where SERFF APIs are available, PK1Cloud will use them. Where appropriate API functionality is missing, we intend to use other technologies to bridge those gaps.
The Real Lesson of SERFF Modernization
SERFF will remain critical regulatory infrastructure. But insurers should not have to build their operating processes around a SERFF user interface or wait for SERFF to deliver every innovation the industry needs.
That is the opportunity we see with PK1Cloud. We can allow SERFF to do what only SERFF can do, connect insurers and regulators, while PK1Cloud provides the technology, workflow, automation, and AI capabilities around it. And as technology changes, PK1Cloud can change with it.
In the end, perhaps the most important lesson from SERFF Modernization is that the most robust and enlightened regulatory system is not the one that attempts to build the best application. It is the one that allows tomorrow’s best applications to connect to it.
Tim Perr
Managing Principal & Chief Executive Officer
Disclosure: I used AI as a research and editing tool in preparing this blog. I reviewed all content, and the views and conclusions expressed are my own.
PK1Cloud brings insurance product development, rate and form filings and compliance workflows into one environment, with SERFF handled behind the scenes. Through the SERFF Modernization transition, our state filings support team and regulatory compliance specialists can help keep your filings moving across both legacy and modernized systems. Contact the PK1Cloud team to see how it works.
