Insights Blog Post

Q3 2025 State Filings Pulse: Texas Common Filing Issues, California Filing Rejection/Withdrawal Rate at Nearly 40%, Approval Times by State and More

Written By Brett Horoff

Reading Time: 5 minutes

Perr&Knight has published the Q3 2025 edition of State Filings Pulse, providing the latest insights into state specific filing news, approval times by state and other filing statistics.

To receive a free copy of State Filings Pulse each quarter, click here to register: https://www.perrknight.com/insights/guides-white-papers/state-filings-pulse/

Key Highlights from the Q3 2025 Edition

Texas Approval Times and Common Filing Issues

During the last 12 months, Texas has disapproved 7% of all filings with a disposition. An additional 7% of the filings were withdrawn during this period.

Approval times in Texas have increased notably for homeowners filings, while remaining relatively steady across other lines of business. Median times to approval are summarized below:

All Lines: Increased from 39 days in 2023 to 57 days for the 12 months ending 09/30/2025
Homeowners: Increased from 70 days in 2023 to 159 days for the 12 months ending 09/30/2025
Personal Auto: Increased slightly from 67 days in 2023 to 71 days for the 12 months ending 09/30/2025
Commercial & All Other Personal: Increased from 30 days in 2023 to 52 days for the 12 months ending 09/30/2025

The Texas Department of Insurance Filings Made Easy Manual outlines common issues found in form and rate/rule filings, which includes the items below.

All Filing Types

Cloned filings: Incorrect information (TOI, Sub-TOI, Filing Type, filing description information, State Specific tab) is uploaded in the new filing which results in additional objections being sent.
Filing company name: Names must match the Certificate of Authority (COA) issued by the Department.
TOI/Sub-TOI: Incorrect for the line of insurance or information being filed.
Line of insurance: Companies must have a COA for the line.
Filing type: Incorrect filing submission. For example, submitting a policy form as an endorsement or including rate/rule pages in form filings.
Managing general agent (MGA): The name that is submitted must match the license that is issued by the Department. Also, the MGA must be appointed by the company.
Risk purchasing groups (RPG): The name of the RPG must be included in the filing. The RPG must be registered with the Department.
Reference filings: Incorrect information submitted.
Documentation: Vague or incomplete filing memorandum. Inaccurately labeled or named documents.

Form Filings

Form name: Must be complete and match the form schedule.
Form number: Must be complete and match the form schedule including the edition date, if applicable.
TDI file number or SERFF tracking number for previously approved policy form: Missing, incorrect, or incomplete.
Form usage table: Incorrect information.

Rate/Rule Filings

Missing or incomplete actuarial support for proposed changes.
Missing one or more categories of required supporting information.
Incomplete information provided on company exhibits. Although the TDI Exhibits themselves are not required, the information requested in them is required. If you use your own version of a TDI exhibit, please make sure it contains at least as much information as the corresponding TDI exhibit. Note that using the TDI exhibits assists TDI staff in reviewing your filing.
Exhibits for a relativity analysis that show an “indicated” factor but do not document the method that produced the factor.
Exhibits that show selected relativities that do not follow the indicated relativities, with no explanation given for the differences between indicated and selected. If the proposed factors are not equal to the indicated factors, the company must explain how the proposed factors are determined from the indicated factors.

The most common objection relates to waiving the 60-day deemer period for form, endorsement, and certificate of insurance filings. The option to waive the deemer date on submission of the filing is included in the State-Specific Questions section in SERFF.

Approximately 25% of form filings approved this year did not include a waiver of the deemer date at the time of initial submission. When insurers elect not to waive the deemer, the Department will request a waiver before starting its review of the filing. While some insurers comply with this request, others choose not to waive the deemer. In many cases, insurers indicate that they will waive or extend the deemer period at a future date if needed.

Form filings where the deemer was not waived had a median time to approval of 18 days, compared to 36 days for filings where the deemer was waived.

California Filing Rejection/Withdrawal Rate at Nearly 40%

Through the third quarter of 2025, insurers continue to struggle to comply with California’s rate filing requirements. Due to a combination of rejections for lack of completeness and withdrawals for other reasons, California recorded the highest combined rejection and disapproval rate in the country, nearly 40% during the second and third quarters of 2025. When combined with approval timelines exceeding nine months, California remains the most challenging state nationwide for obtaining rate filing approval.

There is reason to expect improvement in the near future. One of the primary drivers of filing rejections has been data reconciliation issues. With the release of the October 22, 2025 edition of the state’s transmittal templates, California incorporated its data reconciliation tool directly into the template, allowing insurers to identify and correct discrepancies prior to submission. The updated template also introduces a 5% threshold, requiring differences exceeding that level to be resolved or explained in the Filing Memorandum. Previously, no threshold existed, which often led the Department to question immaterial differences. This concern was raised by one of our consulting actuaries last March during a question-and-answer session with the Department at the Association of Insurance Compliance Professionals Compliance Summit in Los Angeles. We are encouraged that the Department has since implemented a formal threshold.

Looking ahead, California plans to launch the state’s new Prior Approval Rate Application (PARA) Portal in early 2026. Insurers will have the option to complete state transmittal forms though the PARA Portal, which has enhanced data reconciliation and validation tools designed to reduce errors and improve consistency across filings. The Department has begun emailing insurers with no registered PARA Portal users, requesting designation of an initial administrator to complete registration in early January. Additional details and training will be provided by the Department ahead of the PARA Portal release, tentatively scheduled for late January 2026.

Time to Approval/Disposition by State

The table below provides a detailed breakdown, by state, of the median time to approval or disposition, based on data from State Filings Pulse, for the 12-month period ending September 30, 2025.

Rate Filings^1,2

Approval Time Range (Days)	Homeowners	Personal Auto	Commercial & Other Personal
0 to 30³	AL, AR, AZ, ID, IL, IN, KS, KY, LA, MI, MN, MT, NC, NE, NM, OK, OR, SD, TN, UT, WI, WV, WY	AL, AR, AZ, ID, IL, IN, KS, KY, LA, MN, MS, MT, NC, NE, NM, OH, OK, OR, SD, TN, UT, WI, WV, WY	AR, AZ, CT, DC, FL, GA, ID, IN, KS, KY, LA, MA, MI, MN, MS, MT, NC, NE, NH, NM, OH, OK, OR, PA, SD, TN, UT, VT, WI, WV, WY
30 to 59	AK, CO, GA, MO, MS, ND, NH, OH, PA, VA	CT, GA, MA, MI, MO, ND, NH, NV, VA	AK, AL, DE, HI, IA, IL, ME, MO, ND, NV, RI, SC, VA
60 to 89	CT, DE, IA, MA, ME, VT	AK, DE, IA, ME, NJ, PA, RI, SC, TX, VT	NJ, NY, TX
90 to 119	DC, NJ, NV, RI	CO, FL	WA
120 to 149	FL, SC, WA	DC, HI, WA	CO
150 to 179	HI, MD, TX	MD, NY	None
180 to 269	None	None	MD
270 to 359	CA, NY	CA	CA
360+	None	None	None

Excluding Rate Filings^1,2

Approval Time Range (Days)	Homeowners	Personal Auto	Commercial & Other Personal
0 to 30³	AK, AL, AR, AZ, CT, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, ME, MI, MN, MO, MS, NC, ND, NE, NM, NV, OH, OK, OR, PA, RI, SC, SD, TN, UT, VA, VT, WA, WI, WV, WY	AK, AL, AR, AZ, CT, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NM, NV, OH, OK, OR, PA, RI, SC, SD, TN, UT, VA, VT, WA, WI, WV, WY	AK, AL, AR, AZ, CT, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, NC, ND, NE, NH, NM, NV, OH, OK, OR, PA, RI, SC, SD, TN, UT, VT, WA, WI, WV, WY
30 to 59	CO, DC, MA, MD, MT, NH	CO, MA, NH, TX	MT, NJ, NY, TX, VA
60 to 89	NJ, NY	CA, DC, NJ, NY	CO, DC
90 to 119	CA	None	CA
120 to 149	None	None	None
150 to 179	TX	None	None
180 to 269	None	None	None
270 to 359	None	None	None
360+	None	None	None

For states where the filing law is “file and use” or “use and file”, insurers may use the filing prior to the state issuing an approval/disposition.
Includes filings with approval/disposition dates during the period 10/01/2024 to 09/30/2025.
Includes states exempt from filing.

The Q3 2025 edition includes data spanning from January 2020 through September 2025, providing long-term statistics and comparisons across states.