- A filing that draws an objection takes roughly four times as long to approve, and nearly six times as long in Personal Auto, with an objection adding a median of 38 days
- Approval times for P&C rate filings vary by more than 250 days between US jurisdictions: median approvals runs at 252 days in California and 220 days in New York, while Wisconsin clears most filings in under a day
- Homeowners is the most contested line, with a 53.2% objection rate, followed by Personal Auto at 50.7%, and commercial property at 34.3%.
- Regulator objections follow recurring patterns across states, making many approval delays predictable and potentially avoidable.
- The report warns that slow admitted-market approvals are helping push business into the Excess & Surplus market, which has set record share in each of the past three years
A new report by ZestyAI has found that rate filings drawing a regulator objection take roughly four times as long to approve, based on an analysis of 20,183 homeowners, personal auto and commercial property filings across all 50 states. State regulators issued more than 35,000 objection letters against those filings in a single year, and the gap between jurisdictions is stark: a rate change that clears in under a day in Wisconsin takes a median 252 days in California. The report concludes these delays are largely predictable and often avoidable.
Approval Velocity 2026, produced by ZestyAI using its ZORRO Discover regulatory intelligence platform, analyzed 20,183 approved rate filings across all 50 states and the District of Columbia during the 12 months ended May 8, 2026. The research covers Homeowners, Personal Auto and Commercial Property, the three lines with the highest filing volumes.
Of the filings analyzed, 8,776, or 44%, drew at least one formal objection from a state Department of Insurance, generating more than 35,000 individual objection letters. An objection added a median 38 days to the approval process. The penalty was steepest in Personal Auto, where the median filing without an objection closed in 9 days and the median filing with one took 52 days, nearly six times as long.
“The real story in this data is how avoidable the delays are. Many of the questions causing delay are not new; they recur from filing to filing.” said Bryan Rehor, Senior Director of Regulatory and Government Affairs at ZestyAI. “Carriers that anticipate those questions and submit the right evidence from the outset can avoid the objection entirely, and the weeks or months it adds.”
P&C rate filing approval findings
| Line of business | Approved filings analyzed | Objection rate | Median approval without objection | Median approval with objection | Fastest jurisdiction | Slowest jurisdiction |
| Homeowners | 4,297 | 53.2% | 13 days | 56 days | Wisconsin: <1 day | New York: 220 days |
| Personal Auto | 6,339 | 50.7% | 9 days | 52 days | Wisconsin: <1 day | California: 246 days |
| Commercial Property | 9,547 | 34.3% | 7 days | 33 days | Wisconsin: <1 day | California: 252 days |
The analysis found that the state in which a filing is submitted generally has a greater effect on approval time than the line of business.
California and New York rank among the three slowest across all three lines analyzed, while Wisconsin was the fastest in each. Maryland (210 days) also ranked among the three slowest for Personal Auto and Commercial Property, and New Jersey for Homeowners. South Dakota, Alabama, New Mexico and Arkansas were among the fastest jurisdictions.”
Homeowners was the most contested line in the study, closely followed by Personal Auto, while Commercial Property filings were less likely to receive an objection.
The most common objection themes differed by line of business:
- Personal Auto: Generalized Linear Model (GLM) and rating-factor construction support was the most common objection theme in more than 20 states Regulators frequently asked carriers to explain variable selection, validation, segmentation methodology and the construction of new rating factors.
- Commercial Property: Insurance Services Office (ISO) and American Association of Insurance Services (AAIS) Loss Cost Multiplier adoption and supporting documentation was the leading theme in 16 states, the most concentrated single regulatory ask of any line.
- Homeowners: requirements were more state-specific, with catastrophe-exposed states such as Florida, South Carolina and Hawaii focusing on hurricane and wildfire model documentation, and consumer-protection states such as Georgia, Kansas and New York examining individual policyholder rate caps
“Filing quality and preparation can make a measurable difference,” Rehor added. “Knowing what regulators are likely to ask for before filing, and answering those questions in the original submission, can reduce avoidable follow-up and bring products to market weeks or months sooner.”
The analysis identified several procedural requirements that repeatedly account for a large share of objections within individual states, including state-specific forms, checklists, exhibits and attestations that filing teams can address before submission.
The report also points to a structural consequence of slow approvals: the harder it becomes to clear admitted rate filings, particularly in catastrophe-exposed personal lines markets, the more carriers shift volume to the Excess & Surplus market, where filings are not subject to Department of Insurance rate review. The E&S market has set record share in each of the past three years.
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