Article
Updates from the Statutory Accounting Principles Working Group’s March 23, 2026 meeting
April 6, 2026 · Authored by Daniel E. Buttke and Josh Leinum
This report summarizes key activities of the National Association of Insurance Commissioners (NAIC) Statutory Accounting Principles (E) Working Group (SAPWG) at its spring 2026 meeting on March 23, 2026.
SAPWG addressed a variety of topics including valuation manual implementation guidance, interest maintenance reserve (IMR), sale-leaseback accounting, separate account nonadmitted assets, long-term repos, funding agreement-backed note (FABN) disclosures, funds withheld valuation and asset-liability management (ALM) derivatives and more.
Insurance organizations should take note of these changes as they may significantly affect their accounting in 2026 and beyond.
Adopted revisions to statutory guidance
Ref #2025-34: Updates on Economic Scenario Generator and Non-Variable Annuities
Adopted revisions to SSAP No. 3, SSAP No. 51 and SSAP No. 52 provide guidance on the optional implementation period for Valuation Manual revisions related to the economic scenario generator and non-variable annuities. The revisions expand the phase-in disclosure to reflect the APF 2025-04 economic scenario generator phase-in by adding reference to VM-20 and clarify that the VM-22 (non-variable annuities) optional implementation period is reported as a change in valuation basis.
Ref #2025-23: IMR Proof of Reinvestment
Adopted concepts for an IMR proof of reinvestment developed by the IMR Ad Hoc Group. As adopted, the reinvestment template is intended to be a required component for reporting entities seeking to move into, or increase, a net negative IMR balance. The NAIC staff were also directed to continue working with the industry to refine the templates as part of the broader IMR project.
Ref #2025-01: Sale-Leaseback Clarification
Adopted revisions to SSAP No. 22 clarify that sale-leasebacks with restrictions on access to cash or assets received from the sale do not qualify for sale-leaseback accounting and must be accounted for by the seller using the financing method. The clarified guidance applies to all contracts in effect on or after March 23, 2026.
Ref #2025-32: Remove Shaded Text
Adopted revisions to SSAP No. 40, SSAP No. 90, the Summary of Changes and the ‘How to Use’ document delete the shaded text instructions and previously superseded guidance currently shown as shaded text in SSAP No. 40.
Ref #2025-30: Administrative Services Contracts Disclosure Clarification
Adopted revisions to SSAP No. 47 clarify inconsistencies in the net gain or loss calculation disclosure. SAPWG also communicated support for the related annual statement blanks proposal updating Note 18B, gains and losses on administrative services contracts.
Ref #2025-25: Separate Account Nonadmitted Assets
Adopted revisions to SSAP No. 56 address nonadmittance for assets held under the "general account basis" in the separate account. SAPWG also communicated support for related blanks revisions to incorporate nonadmitted assets within the separate account balance sheet and corresponding schedules.
Ref #2025-28: Nonadmittance of Long-Term Repos
Adopted revisions to SSAP No. 103 allow repurchase agreements with maturity dates of more than one year (classified as long-term) to be admitted. The guidance still requires long-term reverse repurchase agreements to be nonadmitted and clarifies how the nonadmittance should be reported.
Ref #2025-31: Updated Coverage Gap Reference
Adopted revisions to INT 05-05 note the Dec. 31, 2024, discontinuation of the Coverage Gap Discount Program and add references to the Centers for Medicare & Medicaid Services manufacturer discount program that began in 2025.
Ref #2025-29: Reporting Clarifications
Adopted revisions communicate support for a blanks proposal to clarify reporting on debt securities and improve consistency in reporting. The proposal addresses comments from parties related to matters such as payment due at maturity, origination balloon payment percentages and Schedule BA maturity date.
Ref #2025-33: Updates to Annual Statement Expense Descriptions and Categories
Adopted revisions communicate support for a blanks proposal to update and modernize expense descriptions and categories in the annual statement blanks. This agenda item does not result in changes to statutory accounting.
Exposed revisions to statutory guidance
All exposed revisions to statutory guidance, unless noted below, are classified as SAP clarifications with the public comment period ending May 1, 2026.
SAPWG initially exposed this item during the fall 2025 meeting, which exposed revisions to SSAP No. 1 to expand paragraph 23b to add reporting for assets held under a modified coinsurance (modco) and funds withheld arrangement. These changes include disclosure of 1) modco assets, 2) funds withheld assets and 3) collateral assets received and, on the balance sheet, excluding collateral held under security lending and repurchase agreements reported on the balance sheet.
At the spring 2026 meeting, SAPWG re-exposed revisions requesting comments on whether to retain the restricted asset codes. SAPWG is reconsidering whether separate codes for modco and funds withheld assets should be added, whether the restricted asset code column should be retained at all, and whether any change should apply to all reporting entities or be limited to life and fraternal entities.
Exposed editorial revisions to various SSAPs would replace the term "CUSIP" with "Security Identifier" add "U.S." before "GAAP" or "generally accepted accounting principles" as appropriate, and remove the word "funding" from the beginning of the paragraph describing Federal Home Loan Bank agreements.
Exposed revisions and a glossary addition to SSAP No. 52 would introduce disclosures for funding agreement-backed notes and other funding agreement-backed structures. The proposal follows a referral from the Macroprudential (E) Working Group and would capture information by structure type, putability, whether debt terms differ from backing funding agreements, maturity distribution, rate type, currency denomination, hedging and book/adjusted carrying value of collateral pledged under these structures.
Exposed revisions to SSAP No. 61 and related annual statement instructions would clarify that funds withheld liabilities should be recorded equal to the book/adjusted carrying value of the corresponding funds withheld assets. The exposure also includes proposed revisions to the life and health annual statement instructions on Schedule S, parts 3, 4 and 5, and the liabilities page and further proposes deleting legacy annual statement instruction language regarding use of SVO fair values.
Exposed draft SSAP No. 109 and issue paper would incorporate new statutory accounting guidance allowing an amortized cost measurement method for a qualifying derivative program. The exposure excludes asymmetrical derivatives and requests comment on transition, reporting and admittance questions.
Exposed draft issue paper details the discussions supporting the adopted statutory trust guidance that allows qualifying items to be reported within the mortgage loan guidance. The underlying guidance, which permits qualifying structures to be captures in SSAP No. 37, was adopted at the fall 2025 meeting with a Jan. 1, 2027, effective date and early application is permitted.
Updates on previously exposed revisions to statutory guidance
Ref #2025-22: IMR Impact to Reinsurance Collateral
SAPWG initially exposed this item during the fall 2025 meeting, which exposed revisions to clarify how IMR eliminated as part of a reinsurance transaction should influence the reinsurance collateral required to receive reinsurance credit. The exposure requested comments on whether different IMR treatment should be considered, specifically whether negative IMR eliminated from reinsurance transactions impact the reinsurance collateral. In other words, should net negative IMR be treated symmetrically with positive IMR, decreasing the collateral requirement upon derecognition?
Based on interested party comments, SAPWG proposed two potential options which were:
- With the asymmetrical approach, only positive IMR (increasing policy reserves) would be required in determining collateral requirements to obtain credit for reinsurance. This method would require additional collateral to obtain credit for reinsurance.
- With the symmetrical approach, both positive and negative IMR (increasing and decreasing policy reserves) would be captured in the determination of collateral requirements to obtain credit for reinsurance. For reinsurance transactions with the allocation of negative IMR, this would reduce the collateral required to obtain credit for reinsurance.
SAPWG has deferred this item until a further response is received from the Reinsurance (E) task force.
