ICT Remains Active During the Legislative Interim
Following adjournment of the 89th Texas Legislature, ICT remained actively engaged throughout the interim by monitoring legislative and regulatory developments, analyzing emerging policy issues, and maintaining communication with lawmakers and state leadership on matters impacting members.
Legislative Monitoring
- Closely monitored both called special legislative sessions for issues with potential impacts on members, including disaster preparedness proposals and legislation related to insurers’ use of aerial imagery in property policy nonrenewals.
- Monitored interim legislative hearings and emerging policy discussions with potential to affect the property and casualty insurance market, including House State Affairs discussions on wildfire preparedness and mitigation ahead of formal interim charge hearings.
Interim Charges & Policy Engagement
- Identified and provided members with timely breakdown of more than 20 House and Senate interim charges with potential implications for the insurance industry, including affordability, consumer protections, disaster preparedness, wildfire mitigation, prompt payment, tort issues, artificial intelligence, data privacy, and autonomous vehicle technology.
- Prepared testimony, feedback, and policy recommendations for interim hearings and legislative discussions affecting the property and casualty insurance market.
Implementation of New Laws
- Monitored implementation and rulemaking related to legislation passed during the 89th Legislative Session to identify regulatory, operational, and market impacts relevant to members.
Elections & Political Analysis
- Provided members with timely recaps and analysis of Texas primary, special, and general election results, highlighting key House and Senate races with potential implications for the insurance industry and the 2027 legislative session.
Member Advocacy & Government Relations
- Maintained ongoing engagement with legislators, legislative staff, regulators, and the offices of the Governor and Lt. Governor to ensure member perspectives remained part of ongoing policy discussions throughout the interim.
- Continued providing members with timely legislative updates, policy analysis, and issue monitoring throughout the interim period as preparation for the 90th Texas Legislature continues.
Monitoring Key Interim Charges
Ahead of the 90th Legislative Session
ICT actively monitored House and Senate interim charges with potential impacts on the property and casualty insurance market and broader business climate in Texas. Areas of focus included insurance affordability and market stability, consumer protections, litigation and tort issues, wildfire mitigation, disaster preparedness, artificial intelligence, data privacy, autonomous vehicle technology, and catastrophe resiliency.
Throughout the interim, ICT provided members with timely analysis and updates on more than 20 interim charges while preparing testimony, feedback, and policy recommendations for legislative hearings and stakeholder discussions.
Primary Committees of Interest
Senate Business & Commerce
Interim Focus Areas:
- Insurance affordability
- Market stability & competitiveness
- Insurer participation & coverage availability
- Consumer protections & regulatory oversight
House Insurance
Interim Focus Areas:
- Appraisal & HB 2067 implementation
- Insurance cost drivers & affordability
- Consumer protections & prompt payment
- TWIA & market stability issues
Additional Interim Charges Monitored
Developing ICT's Legislative Priorities
for the 90th Legislative Session
In preparation for the 90th Texas Legislative Session, ICT launched a collaborative, member-driven process to develop our legislative priorities and policy positions for consideration by the ICT Board ahead of the 2027 legislative session.
Working closely with ICT staff, the Regulatory & Policy Committee helped identify emerging issues, evaluate market trends, and shape strategic priorities to support a strong, stable, and competitive property and casualty insurance market in Texas.
Member Engagement & Policy Development
- Conducted a legislative priorities survey of the Regulatory & Policy Committee, achieving a 62% participation rate and gathering member feedback on issues expected to impact the property and casualty insurance market during the 90th Legislature.
- Utilized member feedback, committee discussions, research, and industry analysis to help shape a loss-reduction-focused legislative strategy centered on market stability, litigation reform, fraud and abuse reduction, catastrophe resiliency, and affordability.
- Continued developing ICT’s legislative agenda through regular Regulatory & Policy Committee meetings focused on identifying emerging issues, refining policy priorities, and preparing recommendations for Board consideration.
Preparing for the 90th Legislature
- Continued refining draft legislative priorities and policy recommendations throughout the interim in preparation for Board review and approval in 2026.
- Began developing draft legislative language and identifying legislative champions for potential priority initiatives ahead of the 90th Texas Legislature.
- Maintained ongoing collaboration with members, legislative stakeholders, and industry partners to ensure ICT remains prepared to effectively advocate on behalf of the property and casualty insurance industry during the 90th Texas Legislative Session.
Member Priority Areas
- Stable & Competitive Regulatory Framework
- Litigation Reform
- Claims Fraud & Abuse Reduction
- Property Resilience & Catastrophe Mitigation
ICT Insuring Texas PAC
In late 2024, ICT established the Insuring Texas PAC in support of the association’s legislative advocacy efforts. As the official political action committee of ICT, the PAC works to advance the interests of Texas property and casualty insurers while supporting a strong and competitive insurance marketplace.
PAC Engagement & Growth
- In its first year of operation, donor support enabled the Insuring Texas PAC to engage key legislators, strengthen relationships with policymakers working on insurance issues, and begin building a foundation for the 2026–27 election cycle.
- PAC contributors receive regular updates and engagement opportunities, including election recaps, policy insights, and information on key policymakers and legislative developments impacting the industry.
Through strategic engagement and support of elected officials who share ICT’s priorities, the PAC helps protect the political and business interests of member companies while promoting policies that support a strong and stable property and casualty insurance market in Texas.
PAC Events & Advocacy
ICT hosted a PAC luncheon during the 2025 ICT Symposium and continued expanding PAC engagement opportunities for members.
On March 4, 2026, the Insuring Texas PAC hosted “Justice, Not Jackpots: Leading the Rally Against Greed,” focused on the industry’s continued efforts to address lawsuit abuse ahead of the 2027 legislative session.
On February 9, 2026, the Insuring Texas PAC, in conjunction with APCIA’s Insuring America PAC, hosted a joint fundraising reception honoring House Insurance Committee Chairman Jay Dean (R–Longview) in Austin. The event highlighted the property and casualty insurance industry’s continued engagement in the legislative process and provided an opportunity to discuss key industry issues.
ICT plans to continue expanding PAC engagement and advocacy efforts throughout the 2026 election cycle.
Bringing the Industry Together:
Collaboration and Strategy
ICT continued to play a leading role in bringing together insurers, trade associations, legislative advocates, and industry stakeholders to collaborate on issues affecting the Texas property and casualty insurance market. Through industry meetings, national engagement, and public outreach, ICT helped foster coordination and strategic discussion on legislative, regulatory, and market challenges facing the industry.
Industry Collaboration
& Trade Meetings
ICT hosted two All Industry Meetings during the interim, bringing together state and national trade associations, industry advocates, and stakeholders to discuss legislative developments, litigation abuse, and emerging issues ahead of the 90th Texas Legislature. ICT also facilitated regular coordination meetings with APCIA, NAMIC, TCAIS, TAMIC, and RAA to discuss key industry priorities, align messaging, and strengthen collaboration on legislative and regulatory issues.
National Industry Engagement
ICT participated in the annual State Insurance Trade Association (SITA) meeting, where insurance trade groups from across the country exchanged strategies and discussed national trends related to litigation abuse, underwriting standards, fraud, artificial intelligence, wildfire risk, electric vehicles, and rising insurance costs. ICT also continued participating in National Council of Insurance Legislators (NCOIL) meetings throughout the year to stay informed on national legislative trends, model laws, and emerging policy discussions affecting the insurance industry.
Public Outreach & Education
ICT Executive Director Albert Betts provided an overview of the Texas property and casualty insurance market to the Richardson Rotary Club, highlighting market conditions, catastrophe exposure, insurance regulation, litigation trends, and industry efforts to maintain a competitive and stable marketplace for Texas consumers.
Through ongoing collaboration with state and national partners, ICT continues strengthening the industry’s collective advocacy efforts.
Regulatory Efforts
Texas Department of Insurance (TDI)
ICT supports its members by monitoring regulatory developments at the Texas Department of Insurance (TDI), providing timely updates, and engaging on rulemakings impacting the property and casualty insurance market. Through ongoing collaboration with regulators and stakeholders, ICT helps ensure member perspectives remain part of the regulatory process.
Cassie Brown
Former Texas Insurance Commissioner
TDI Leadership Transition & Engagement
The year brought significant leadership changes at TDI with the retirement of Commissioner Cassie Brown and Governor Greg Abbott’s appointment of Amanda Crawford as Texas Commissioner of Insurance in February 2026.
ICT engaged with Commissioner Crawford and TDI leadership through TDI’s “Meet the Regulator” event and direct meetings to discuss issues affecting the property and casualty insurance market. Commissioner Crawford emphasized transparency, consistent regulatory standards, and open communication with stakeholders.
ICT looks forward to continued engagement with Commissioner Crawford and TDI leadership.
Amanda Crawford
Current Texas Insurance Commissioner
ICT Engages on:
TDI Unearned Premium Refund Rule
In September 2025, ICT submitted comments on TDI's proposed amendments relating to unearned premium refunds for personal auto and residential insurance policies. ICT’s comments focused on ensuring clarity regarding the treatment of premiums, fees, and surcharges, preserving insurers’ ability to retain minimum earned premiums for unrecoverable policy issuance expenses, and providing sufficient implementation time for system and compliance updates.
The final rule, adopted in January 2026, incorporated several revisions responsive to stakeholder feedback, including input from ICT, clarifying the treatment of premiums versus fees and surcharges, preserving insurers’ ability to retain certain minimum earned premiums, and extending the implementation timeline to allow additional time for compliance updates.
TDI Appraisal Rulemaking
In October 2025, ICT submitted comments on TDI’s informal draft rule implementing SB 458, which requires appraisal provisions in residential property and personal auto insurance policies. ICT advocated for a balanced implementation approach that preserves insurers’ flexibility to continue using approved appraisal provisions while addressing operational issues such as appraisal timelines and appraiser and umpire qualifications.
In May 2026, TDI formally proposed rules implementing SB 458, incorporating several technical changes responsive to stakeholder feedback, including input from ICT. On June 2, ICT testified at TDI's public hearing on the proposed rules, and on June 8, ICT submitted formal written comments. ICT continues engaging in the rulemaking process on behalf of members as the rules move toward final adoption.
HB 2067 Implementation and Reporting Requirements
Following testimony at TDI’s November 13, 2025 public hearing, ICT submitted written comments on implementation of the residential and private passenger auto portion of HB 2067 (Phase 1), which requires insurers to provide reasons for policy declinations, cancellations, and nonrenewals and to report related information to TDI. ICT advocated for a practical implementation timeline and phased reporting approach prioritizing compliance with the law’s consumer notice requirements.
In January 2026, TDI adopted the final rules and statistical plan updates implementing Phase 1 of HB 2067, including revisions responsive to stakeholder feedback that extended implementation timelines and clarified certain reporting obligations.
On June 22, ICT submitted comments on TDI's proposed rules for Phase 2 implementation of HB 2067, which would require certain commercial line insurers to report declination, cancellation, and nonrenewal data through the updated Texas Commercial Lines Statistical Plan. ICT encouraged TDI to delay implementation until January 1, 2027, clarify the proposal's applicability across commercial lines, protect confidential insurer information, and ensure the reporting requirements remain consistent with the statute. ICT also testified during TDI's June 15 public hearing.
ICT Submits Comments on Consumer Bill of Rights Revisions
On June 15, ICT submitted comments on TDI's proposed revisions to the Personal Auto and Homeowners Consumer Bills of Rights, which implement legislation passed during the 89th Texas Legislature. ICT recommended additional implementation time for insurers and several technical revisions to improve consistency with the underlying statutes. TDI is currently reviewing stakeholder comments before adopting final rules.
Texas Department of Insurance, Division of Workers’ Compensation (DWC)
ICT continued monitoring regulatory and policy developments at the Texas Department of Insurance, Division of Workers’ Compensation (DWC), to help members stay informed on issues impacting the Texas workers’ compensation system. Through ongoing engagement, regulatory analysis, and collaboration with members and counsel, ICT provided timely updates and coordinated industry input on emerging workers’ compensation issues.
Regulatory Monitoring & Member Support
- ICT proactively monitored DWC rulemaking, bulletins, reports, stakeholder meetings, and other regulatory developments affecting the Texas workers’ compensation system.
- ICT provided members with timely updates, summaries, and analysis regarding regulatory activity and emerging issues relevant to workers’ compensation insurers and stakeholders.
Workers’ Compensation Advisory Committee
- ICT worked closely with the Workers’ Compensation Advisory Committee to review regulatory developments and coordinate member feedback on proposed DWC rules and policy issues.
- The committee helped ensure member perspectives remained part of ongoing regulatory discussions impacting the workers’ compensation market and remained prepared to engage on significant regulatory issues affecting members.
Recaps of DWC Insurance Carrier Quarterly Meetings
- ICT's workers' compensation regulatory counsel, Burns Anderson Jury & Brenner LLP provided detailed recaps of DWC Insurance Carrier Quarterly Meetings.
- Meeting recaps and regulatory resources were made available to members through ICT’s online InfoHUB.
Other Regulatory Efforts
ICT Coordinates Industry Response on Proposed SB 17 Rule
In April 2026, ICT coordinated with APCIA, NAMIC, and IIAT to submit joint comments on the Office of the Attorney General’s proposed rule implementing SB 17, which restricts certain foreign ownership of real property in Texas. The proposed rule identified property insurers as “facilitating entities” responsible for reporting potentially prohibited transactions.
Following member feedback, ICT worked with industry partners to raise concerns that the proposed reporting requirements exceeded the scope of the statute and would create significant operational challenges for insurers, who are not positioned to investigate property ownership transactions.
Monitoring the Residual Markets – TWIA and FAIR Plan
ICT Monitors TWIA and FAIR Plan Activities
ICT closely monitors all Texas Windstorm Insurance Association (TWIA) and FAIR Plan meetings to ensure members receive timely, relevant updates. ICT provides clear, concise summaries of key discussions and reports, including TWIA’s annual and biennial reports to the Texas Legislature. ICT also submits letters and formal comments on behalf of members to advocate on critical issues.
ICT Submits Comments on TWIA 2026 Rate Filing
ICT, joined by NAMIC, submitted comments supporting TWIA’s actuarial recommendation for a 3% residential and 5% commercial rate increase for 2026, emphasizing the importance of actuarially sound ratemaking and the need to minimize cost shifting to policyholders and insurers through assessments and surcharges.
While TWIA’s actuarial indication reflected reduced reinsurance needs and other financial changes, the TWIA Board ultimately voted to approve a 0% rate increase for both residential and commercial policies at its August 2025 meeting in Galveston.
ICT Supports Updated TWIA Building Code Standards
ICT submitted comments supporting TDI’s proposed updates to TWIA building code requirements incorporating the 2024 International Residential Code (IRC) and 2024 International Building Code (IBC) standards for structures insured by TWIA in designated catastrophe areas. ICT emphasized that stronger building standards help improve resilience in catastrophe-prone areas, reduce storm-related losses, and support long-term market stability and affordability.
TDI subsequently adopted the updated rules, including revisions responsive to stakeholder feedback that extended the implementation timeline to April 1, 2026, to allow additional time for compliance. TDI also acknowledged ICT’s comments supporting resilient building standards and their role in reducing future losses.
TWIA Annual Report Recap
ICT provided members with a detailed recap of TWIA’s 2025 Annual Report through the ICT InfoHUB, highlighting policy growth, exposure trends, premium history, funding structure, and implementation updates related to legislation passed during the 89th Legislature.
ICT Monitors TWIA Catastrophe Funding Discussions
ICT closely monitored TWIA’s 2026 catastrophe funding discussions and Board actions related to the association’s Probable Maximum Loss (PML) and reinsurance structure. In February 2026, the TWIA Board finalized a $4.3 billion 1:50 PML for the 2026 hurricane season and approved plans to pursue approximately $2.28 billion in reinsurance coverage.
ICT closely followed these discussions given the potential financial implications for member companies, particularly proposals involving reinsurance above the statutory funding threshold, which could result in direct assessments on TWIA member insurers. ICT remained engaged throughout the process and prepared to advocate on issues impacting members and the broader property insurance market.
ICT Engages on FAIR Plan POA Insurance Expansion
In June 2026, ICT submitted comments and testified at a TDI public hearing regarding petitions seeking to designate portions of the Clear Lake area in Harris County as underserved for purposes of property owners’ association (POA) insurance through the Texas FAIR Plan Association.
ICT raised concerns that the petitions did not satisfy statutory requirements for underserved area designation, relied improperly on insurance cost rather than availability, and represented a significant expansion of FAIR Plan coverage that should proceed through a formal rulemaking process with stakeholder input. ICT also emphasized concerns regarding expansion of FAIR Plan coverage to nonresidential risks.
Following the hearing and comment process, TDI ultimately designated portions of the Clear Lake area as underserved for POA insurance. ICT’s engagement helped ensure industry concerns regarding statutory compliance, market impacts, and transparency were part of the regulatory discussion.