How Long Does It Take to Get a P&C Rate Filing Approved? New Data Across All 50 States

A rate filing submitted in Wisconsin can be approved in a single day. A similar filing in California can take more than eight months. Across the United States, that gap now exceeds 250 days

For P&C insurers, approval velocity is no longer a back-office compliance metric. It is a business constraint that affects pricing agility, product availability, rate adequacy, admitted-market competitiveness, and the shift toward Excess & Surplus. 

ZestyAI analyzed 20,183 approved P&C rate filings across all 50 states and the District of Columbia for the 12 months ended May 8, 2026. The analysis covers the three highest-volume filing lines in the country: Homeowners, Personal Auto, and Commercial Property.

The analysis was conducted using ZORRO Discover, ZestyAI’s AI-powered regulatory and competitive intelligence platform for P&C insurance, which indexes more than 2 million regulatory filings and 200 million pages.

The result is the Approval Velocity 2026 report: a state-by-state benchmark of how long P&C rate filings take to get approved, where regulator objections occur most often, and what filing teams can do to reduce avoidable delay.

Key Findings

Across every approved P&C rate filing in the last 12 months, 20,183 across homeowners, commercial property, and personal auto, ZestyAI found six patterns that matter for underwriting, actuarial, product, and regulatory teams: 

1. Approval times vary by more than 250 days between the fastest and slowest states. Wisconsin and South Dakota close most filings in 0–2 days; California, New York, and Maryland can take 6–8 months.
2. 44% of approved rate filings drew at least one regulator objection. Across the dataset, 8,776 filings received at least one formal objection letter before approval.
3. A single regulator objection adds a median of 38 days to approval time. In some states, the added delay exceeds 150 days. 
4. Personal lines draw materially more scrutiny than commercial lines. Homeowners filings received objections 53% of the time. Personal Auto filings received objections 51% of the time. Commercial Property filings received objections 34% of the time. 
5. Personal Auto objections are highly concentrated. GLM and rating-factor construction support is the dominant objection theme in more than 20 states, making it the most repeatable documentation opportunity in the dataset. 
6. Filing friction is one operational force accelerating the shift toward E&S. When admitted filings take months to clear, carriers face longer periods of rate inadequacy, missed effective dates, and heavier operational burden. 

Approval Times Vary by More Than 250 Days Across States

Across Homeowners, Personal Auto, and Commercial Property filings, the gap between the fastest and slowest states exceeds 250 days. 

The fastest states move quickly. Wisconsin, South Dakota, Alabama, and Arkansas close many filings in zero to two days. The slowest jurisdictions, including California, New York, Maryland, New Jersey, and South Carolina, can take six to eight months. 

This pattern appears across all three lines studied. Whether a filing moves quickly or stalls is driven more by the state than by the line of business.

For carriers, that makes state-level approval velocity one of the most important variables in filing strategy. A national approval assumption is not useful. Filing teams need state-specific expectations for effective dates, launch sequencing, objection planning, and resource allocation.

44% of Approved Filings Drew at Least One Regulator Objection

Of the 20,183 approved filings analyzed, 44% — or 8,776 filings — drew at least one formal objection letter from the state Department of Insurance before approval. Across the 12-month dataset, regulators issued more than 35,000 individual objection letters.

The cost of an objection is significant: when a filing draws one, it takes roughly four times as long to approve compared to a filing that clears without comment. The median delay an objection adds is 38 days across all lines.

The objection rate is meaningfully higher for personal lines than commercial. Homeowners filings drew objections 53% of the time. Personal Auto drew objections 51% of the time. Commercial Property, where DOIs apply lighter regulatory scrutiny to commercial pricing, drew objections 34% of the time. 

That is not simply a quality-of-filing issue. It reflects a deliberate regulatory posture: state DOIs apply heavier scrutiny to consumer-facing personal lines pricing. 

Homeowners Rate Filings: The Most Contested Line

4,297 approved filings. 53.2% objection rate. Median approval time: 36 days.

Homeowners is the most contested of the three lines studied. It is also the most heterogeneous: unlike Personal Auto and Commercial Property, where objection themes cluster around one or two dominant patterns, Homeowners themes are highly state-specific.

CAT-exposed states focus on catastrophe model documentation  

In CAT-exposed states, regulators frequently focus on catastrophe model support.

Florida, Hawaii, Maryland, Montana, and South Carolina show strong focus on hurricane-model vendor disclosure, catastrophe-model documentation, FCHLPM compliance, and ASOP 38/41 attestations.

Hawaii and South Carolina stand out. Hawaii homeowners filings drew objections 92% of the time. South Carolina homeowners filings drew objections 95% of the time.

For carriers filing in CAT-exposed states, catastrophe model documentation should not be treated as supporting material. It should be treated as a core filing asset.

Consumer-protection states focus on policyholder impact 

In consumer-protection states, regulators focus heavily on how rate changes affect individual policyholders.

Arkansas, Georgia, Kansas, Mississippi, New York, and Pennsylvania show greater scrutiny of individual-policyholder rate impacts.

New York is the clearest example. Its dominant homeowners objection theme is aggressive individual-policyholder rate capping, including strict maximum-percentage-change limits. New York’s median homeowners approval time was 220 days, the slowest homeowners approval timeline in the dataset.

For carriers, actuarial indication alone is not enough. Filing packages need to explain how rate changes affect individual policyholders, not just the overall rate level.

Actuarially rigorous states focus on model construction and reconciliation 

California, Iowa, and Nebraska show greater scrutiny of GLM construction, trend support, and indication reconciliation.

California homeowners filings received objections 100% of the time in the dataset. That reflects the granular line-by-line reconciliation required under the state’s Prior Approval Rate Application and Standard Exhibits Template.

For actuarial teams, every model choice, trend assumption, and reconciliation step needs to be regulator-ready before submission.

Fastest and slowest states for Homeowners filings

The slowest Homeowners states were New York at 220 days, California at 197 days, and New Jersey at 177 days.

The fastest Homeowners states were Wisconsin at 0 days, South Dakota at 1 day, and Alabama at 2 days.

When an objection lands in a slow state, the delay compounds. In Georgia, the median homeowners filing closed in 30 days without an objection and 187 days with one, a 157-day swing. Washington and New York each added more than 140 days when an objection was issued.

Personal Auto Rate Filings: The Highest Objection Volume

6,339 approved filings. 50.7% objection rate. Median approval time: 33 days.

Personal Auto generated more individual objection letters than any other line in the study — 12,793, compared to 12,310 for Homeowners and 10,486 for Commercial Property. The median objection in Auto adds 39 days to approval time, the largest penalty of any line. California's median of 246 days is the slowest in the entire dataset.

GLM and rating-factor support dominates Personal Auto objections

Unlike Homeowners, Personal Auto objection themes are highly concentrated.

GLM and rating-factor construction support is the dominant objection theme in more than 20 states. This reflects regulators’ sharpened focus on segmentation methodology as carriers introduce new rating constructs, telematics programs, credit-based scoring models, and by-peril rating approaches.

The practical implication is significant. Carriers introducing new rating factors can build one regulator-ready documentation package and reuse it across many states.

That package should include variable selection rationale, model form support, hold-out validation, lift analysis, multicollinearity testing, indication reconciliation, bias testing, and a clear explanation of how rating factors affect policyholder premium.

This is not just a compliance exercise. It is a speed advantage. Better model documentation can reduce back-and-forth and help carriers move faster through high-scrutiny states.

Fastest and slowest states for Personal Auto filings

The slowest Personal Auto states were California at 246 days, Maryland at 142 days, and New York at 131 days.

The fastest Personal Auto states were Wisconsin at 0 days, South Dakota at 1 day, and New Mexico at 3 days.

The with-objection versus no-objection gap is stark. The median Personal Auto filing without an objection closed in 9 days. With an objection, the median increased to 52 days, nearly six times longer.

New York had the widest swing: 71 days without an objection versus 200 days with one.

Commercial Property Rate Filings : Faster Overall, But Risky at the Slow End 

9,547 approved filings. 34.3% objection rate. Median approval time: 13 days.

Commercial Property is the least contested line in the analysis, with the lowest objection rate and the fastest overall median approval time. Most commercial property filings clear without ever drawing a regulator comment. When they do draw one, though, the delay is severe: the median commercial property filing closes in 7 days without an objection, and 33 days with one — nearly five times longer.

ISO and AAIS loss cost support drives many Commercial Property objections

Sixteen states share the same dominant Commercial Property objection theme: ISO/AAIS Loss Cost Multiplier adoption and support.

For carriers deviating from ISO loss costs, the filing package should include a standardized comparison exhibit that allows reviewers to verify the deviation quickly.

That exhibit should show the ISO baseline, the company loss cost multiplier, the resulting rate by class, support for deviations, and expected impact on indicated and selected rates.

This is one of the highest-value documentation opportunities in the dataset because the objection theme is both common and predictable.

Fastest and slowest states for Commercial Property filings

The slowest Commercial Property states were California at 252 days, Maryland at 210 days, and New York at 108 days.

The fastest Commercial Property states were Wisconsin at 0 days, Alabama at 1 day, and Arkansas at 1 day.

Maryland illustrates the risk at the slow end. The median Commercial Property filing there closed in 124 days without an objection and 259 days with one, a 135-day gap. New York increased from 41 days without an objection to 145 days with one.

Four Patterns That Hold Across All Three Lines

The Approval Velocity 2026 report reveals four consistent patterns across Homeowners, Personal Auto, and Commercial Property. 

State posture dominates line-of-business posture. 

Whether a filing takes days or months is determined more by where you file than what you're filing. California, New York, Maryland, and South Carolina are slow in Homeowners, Personal Auto, and Commercial Property alike. Wisconsin, South Dakota, Arkansas, and Alabama are fast across all three. Carriers building multi-state filing plans should treat state posture as the primary variable.

Personal lines draw materially more scrutiny than commercial. 

Homeowners and Personal Auto filings draw objections more than half the time. Commercial Property filings draw objections about one-third of the time.

This is not necessarily a quality-of-submission problem. It reflects a deliberate regulatory posture. State DOIs apply heavier review to consumer-facing personal lines pricing.

Objection themes vary by line

Homeowners objections are highly state-specific. CAT-exposed states focus on catastrophe model support. Consumer-protection states focus on policyholder impacts. Actuarially rigorous states focus on model construction and reconciliation.

Personal Auto objections are more standardized. GLM and rating-factor support is the dominant issue in more than 20 states.

Commercial Property objections are also concentrated. ISO/AAIS LCM adoption and support is the dominant issue in 16 states.

Each line needs a different preparation strategy.

Many objections are avoidable 

A significant share of objections are not substantive disputes over rate adequacy. Many are procedural asks that can be anticipated before submission.

Examples include Connecticut requiring the Rate Matrix and Readable Language Certification, Illinois requiring Maximum and Minimum Percentage Change values plus a rate-impact breakdown under the Rate/Rule tab, Michigan requiring the P&C Rate/Rule Filing Checklist v5 with a matching SERFF number, and Ohio requiring INS 4012 with Ohio and countrywide profit and loss data.

These issues are preventable. Filing teams that build state-specific pre-submission checklists can remove avoidable delay from the approval process.

Why Approval Velocity Matters for P&C Insurers

Approval velocity is the time between when a carrier submits a rate filing and when the state Department of Insurance approves it.

That timeline has become a strategic constraint. In fast states, carriers can respond quickly to changing loss costs, catastrophe exposure, and underwriting performance. In slow states, pricing updates can sit in review for months, leaving teams managing business against rates that may no longer reflect current risk.

For underwriters

Slow approval velocity means pricing can lag the actual risk environment.

When a rate filing takes 150, 200, or 250 days to approve, underwriters may continue writing business under rates that no longer reflect current loss costs, catastrophe exposure, inflation, or portfolio strategy.

That gap is especially important in states exposed to wildfire, hurricane, severe convective storm, non-weather water, and other fast-changing loss drivers.

Approval velocity should inform underwriting strategy. In slow states, carriers may need tighter appetite management, more disciplined renewal segmentation, and earlier filing preparation to avoid prolonged exposure to stale pricing.

For actuaries

For actuaries, the data shows where stronger support can reduce delay.

In Personal Auto, GLM and rating-factor support is the dominant objection theme in more than 20 states. In Commercial Property, ISO/AAIS LCM support is the dominant objection theme in 16 states. In Homeowners, state-specific documentation is critical, especially for catastrophe models, individual policyholder impacts, and indication reconciliation.

Actuarial teams should treat objection prevention as part of model deployment.

The best filing support does not simply show the selected rate. It explains the path from data to indication to selected rate to policyholder impact in a way the regulator can verify.

For product managers

For product managers, approval velocity changes launch planning.

A product rollout that assumes uniform regulatory timing will be wrong. Fast states may clear in days. Slow states may not clear for months.

That means product teams should plan state sequencing around approval velocity, not just market opportunity. In some cases, the best launch path may be to move quickly in fast-approval states while preparing more robust documentation for high-friction states.

Approval velocity should be part of the product roadmap, especially when launching new rating variables, by-peril rating structures, telematics programs, catastrophe model updates, or major segmentation changes.

The E&S Market Signals Hidden in The Data

There is a structural consequence that extends beyond filing operations. The harder it becomes to clear admitted rate filings — particularly in CAT-exposed, high-cost personal lines markets — the more carriers shift volume to the Excess & Surplus market, where filings are not subject to DOI rate review. The P&C E&S market has set record share in each of the past three years.

This report quantifies one of the operational pressures driving that shift. When a homeowners carrier in New York faces a 220-day median approval cycle, or when every single California filing in a given line draws at least one objection, the admitted market becomes operationally expensive in ways that compound over time: missed effective dates, rate inadequacy during the review window, and filing resources tied up in back-and-forth cycles rather than productive work.

For CEOs, chief underwriting officers, chief actuaries, and product leaders, approval velocity should be viewed as a market strategy input, not just a filing metric. 

State Benchmarks at a Glance

For quick reference, here are the median approval times for the slowest and fastest states in each line:

Homeowners

• Slowest: New York (220d), California (197d), New Jersey (177d)
• Fastest: Wisconsin (0d), South Dakota (1d), Alabama (2d)

Personal Auto

• Slowest: California (246d), Maryland (142d), New York (131d)
• Fastest: Wisconsin (0d), South Dakota (1d), New Mexico (3d)

Commercial Property

• Slowest: California (252d), Maryland (210d), New York (108d)
• Fastest: Wisconsin (0d), Alabama (1d), Arkansas (1d)

Methodology

The Approval Velocity 2026 report covers approved rate filings in all 50 states and the District of Columbia for the trailing 12 months ended May 8, 2026, across Homeowners, Personal Auto, and Commercial Property. Filings that change only forms or rules without a rate change were excluded, as were withdrawn filings. Filings with a 0% overall rate impact were included alongside filings with positive or negative changes; carriers use 0% filings to modernize pricing architecture while holding aggregate premium constant. Approval time is measured from submission date to the date the state DOI closes and approves the filing.

The analysis was conducted using ZORRO Discover, ZestyAI's AI-powered competitive intelligence platform for P&C insurance, which indexes 2 million+ regulatory filings and 200 million+ pages.

For the full state-by-state data, approval time charts, and objection theme breakdowns for all 51 jurisdictions across all three lines, download the complete Approval Velocity 2026 report.