US NAIC Spring 2026 National Meeting Highlights: International Insurance Relations (G) Committee; Aggregation Method Implementation (G) Working Group

The International Insurance Relations (G) Committee (the “(G) Committee”) of the US National Association of Insurance Commissioners (“NAIC”) met on March 24, 2026 at the NAIC’s Spring 2026 National Meeting in San Diego, California. The following are highlights from the meeting. In addition to routine matters, such as adoption of the minutes from the (G) Committee’s Fall 2025 National Meeting and its meetings on February 3, 2026 and February 19, 2026, the (G) Committee addressed the following matters.

Adoption of Aggregation Method Implementation (G) Working Group Report

The (G) Committee received and adopted the report of the Aggregation Method Implementation (G) Working Group (“AMI WG”), which met on March 23, 2026. The AMI WG was created by the NAIC in early 2025 to facilitate domestic implementation of the Insurance Capital Standard (“ICS”) via the US Aggregation Method (“AM”). The following are highlights from the AMI WG meeting.

US Group Solvency Regulation

The AMI WG discussed the draft outline of its review of US Group Solvency Regulation and Implementation of the ICS via the AM, including its recommendations to address issues raised during the comparability assessment conducted by the International Association of Insurance Supervisors (the “IAIS”). In December 2024, the IAIS adopted the ICS, a global risk-based capital framework designed to assess the capital adequacy of Internationally Active Insurance Groups (“IAIGs”). The IAIS intends with the ICS to provide a common, comparable language for supervisors to discuss capital adequacy and evaluate group solvency across different jurisdictions. The IAIS also determined, in October 2024, following a comparability assessment of the ICS and AM, that the AM developed by the United States provides a basis for implementation of the ICS to produce comparable outcomes. However, the IAIS did highlight two areas for which work as part of the finalization of the AM by US regulators will help to ensure convergence of outcomes with the ICS: treatment of interest rate risk, and timing of supervisory intervention.

The AMI WG’s draft review is based on work conducted by a technical drafting group formed in June 2025. The draft review covers four principal areas: (1) use of scalars and choice of regulatory intervention points, including an already-adopted recommendation to move from an unscaled approach to the Excess Relative Ratio (“ERR”) approach calibrated at 200% of the NAIC Risk-Based Capital Authorized Control Level; (2) sensitivity of US life insurance reserves and the AM to changes in interest rates; (3) supervisory intervention of US groups on group capital grounds, including a review of existing tools such as the Group Capital Calculation (“GCC”) and the Own Risk and Solvency Assessment (“ORSA”); and (4) reporting and disclosure requirements, which remain under development at the IAIS.

During the discussion, AMI WG members considered—but did not reach a consensus on—how public disclosure requirements under the AM would be reconciled with existing confidentiality restrictions under the current GCC regime, as well as with international reporting expectations for the ICS. AMI WG Chair Rebecca Easland noted that the remaining ICS disclosure standards are still being finalized at the IAIS level.

The AMI WG’s review’s overall conclusion is that the US framework provides a robust basis for implementation of the ICS via the AM, and that the AM captures relevant risks through the interaction of entity-level requirements and group-level supervisory tools. Where regulatory gaps were identified, the review proposes targeted recommendations related to the AM and changes to the GCC and ORSA. Among the specific recommendations, the review proposes that the ORSA guidance manual be clarified to specify that the GCC is an appropriate measure of regulatory capital at the head of the IAIG level, which would strengthen the connection between existing US supervisory tools and ICS implementation requirements.

The AMI WG voted to expose the draft Review of US Group Solvency Regulation for a 45-day public comment period, with comments to be submitted by May 11, 2026.¹ The AMI WG tentatively expects to hold a regulator-only session on May 21 to review the exposure feedback, followed by an open call on June 2 to discuss feedback and possible refinements, and a vote to approve an updated version of the draft review on June 11. Once approved, the review and recommendations will be submitted to the (G) Committee for adoption, which is expected at the NAIC Summer 2026 National Meeting. Recommendations requiring changes to the GCC and ORSA will be referred to the Financial Condition (E) Committee for implementation. Relevant recommendations will also be incorporated into the documentation for the Final AM, with updates to the Final AM documentation expected in the second half of 2026.

International Association of Insurance Supervisors Committee Updates

A significant portion of the (G) Committee meeting was devoted to a series of presentations on the priorities and work plans of the IAIS Committees. 

• Implementation Assessment Committee: Commissioner Ricardo Lara (CA) provided an overview of the Implementation Assessment Committee (“IAC”), which focuses on how global insurance standards are implemented across IAIS member jurisdictions. The IAC’s work in 2026 will center on its ICS implementation assessment activities, including assessing US implementation of the ICS via the AM.
• Monitoring and Risk Assessment Committee: Commissioner Nathan Houdek (WI) presented on the Monitoring and Risk Assessment Committee (“MRC”, formerly the Macroprudential Committee), which oversees IAIS activities on global insurance risk monitoring, including the annual Global Monitoring Exercise (“GME”) and the publication of the Global Insurance Market Report (“GIMAR”). The GME covers both individual insurer monitoring and sector-wide monitoring, with data collection underway and analysis occurring over the summer. Results are reflected in the year-end GIMAR and reported to the Financial Stability Board.²
• Standards and Supervisory Practices Committee: Director Judith French (OH) presented on the Standards and Supervisory Practices Committee (“SSC,” formerly the Policy Development Committee), which is responsible for developing effective, proportionate, and globally relevant supervisory standards, including Insurance Core Principles (“ICPs”) and the Common Framework for the Supervision of Internationally Active Insurance Groups (“ComFrame”). The SSC’s 2026 priorities include developing ComFrame standards related to ICP 9 (Supervisory Review and Reporting) and ICP 20 (Public Disclosure), developing supporting materials on ICS implementation, and completing projects relating to corporate governance and risk-based solvency regimes.
• Climate Risk Steering Group: Commissioner Grace Arnold (MN) presented on the Climate Risk Steering Group (“CRSG”), which leads IAIS’s work on climate-related risks across the global insurance sector. The CRSG’s work includes strategic coordination of climate initiatives across IAIS projects, financial stability analysis to inform climate-related inputs to the GME and GIMAR, and climate scenario analysis and data collection. In 2026, the CRSG will develop a member-only report on climate-related risk metrics for disclosure and reporting, and examine how climate risk analysis is conducted by IAIS members.

International Cooperation Activities

At its February 3 and February 19, 2026 meetings, the minutes of which were adopted at the Spring 2026 National Meeting, the (G) Committee approved NAIC comment letters on three significant international consultations: (1) the IAIS public consultation on draft revised application papers on recovery and resolution planning; (2) the IAIS public consultation on ICS-related ComFrame material under ICP 9 and ICP 20; and (3) the Financial Stability Board’s public consultation on the scope of insurers subject to recovery and resolution planning requirements. These submissions reflect the NAIC’s continued active engagement in shaping international insurance regulatory standards.

The (G) Committee also heard an update on the NAIC’s international cooperation activities. The NAIC has joined the Association of Insurance Supervisors of Latin America (“ASSAL”) as an associate member, furthering the NAIC’s engagement with Latin American regulators. The (G) Committee discussed recent and upcoming meetings with groups including the ASSAL, the Organization for Economic Cooperation and Development (“OECD”), the Canadian Council of Insurance Regulators, and the Sustainable Insurance Forum.

Finally, the NAIC 2026 International Insurance Forum is scheduled for May 7-8, 2026 in Washington, DC. The Forum provides an opportunity for regulators, industry representatives, and other stakeholders to engage on key international insurance regulatory developments, including ICS implementation and other IAIS initiatives. 

To view additional updates from the US NAIC Spring 2026 National Meeting, visit our meeting highlights page.

¹ The exposure draft of the Review of US Group Solvency Regulation is available to view on the AMI WG page of the NAIC’s website.

² The Financial Stability Board (“FSB”) is an international body, established in 2009 by G20 leaders, that monitors and makes recommendations about the global financial system. The IAIS is a member of the FSB.