US NAIC Spring 2026 National Meeting Highlights: Producer Licensing (D) Task Force
On March 23, 2026, the Producer Licensing (D) Task Force (“PLTF”) met at the Spring 2026 US National Meeting of the National Association of Insurance Commissioners (“NAIC”). In addition to routine matters, such as adoption of the minutes from a prior meeting, the meeting covered the following matters.
2026 PLTF Priorities
The meeting began with a reminder of the priorities for PLTF for 2026, including:
- Review Section 1033 guidelines;
- Complete review and update of the State Licensing Handbook;
- Survey states on uniformity and reciprocity;
- Evaluate the security or remote licensing exams;
- Review continuing education (CE) course guidelines
- Review adjuster guidelines, with a specific focus on the Designated Home State; and
- Advance uniformity for appointment terminations for cause and state-to-state transfers.
NIPR Launch of Revised Uniform Licensing Application
National Insurance Producer Registry (“NIPR”) reported that the revised Uniform Licensing Application will go live on April 10, 2026, which will replace both the former producer and adjuster applications. Revisions to the application include clarified attestation and background question language, more detailed questions regarding criminal history and financial status and administrative proceedings, the addition of a citizenship question to individual renewal applications, the addition of a FINRA CRD number field to both individual and business entity renewal applications, and updated terminology and instructions. NIPR has worked with both industry stakeholders and regulators in preparation for the rollout, with a particular focus on supporting the back-office systems that will need to handle the changes.
NIPR also announced that it will be launching a modernized version of its licensing website called LicenseHub, where insurance professionals can go to apply for and manage their licenses, during Summer 2026. NIPR will also kick off other improvements during the summer, including a redesign of the Attachment Warehouse, and expects to roll out those improvements in 2027.
Appointment Termination for Cause Form
The Securities and Insurance Licensing Association (“SILA”) presented on its proposed electronic form to report Agent Termination of Company Appointment for Cause (“e-Notification Form”), which emerged from a SILA subgroup discussion focused on the current termination for cause process. SILA identified several pain points with the current system, including inconsistencies across various states of existing termination for cause notification processes and information requested by states, the inability of many state systems to accept termination for cause notifications through the NIPR reporting platform, and the fact that current termination for cause reports tend to be high-level only—often prompting states to request supplemental information and extending the time needed to process each termination.
SILA presented its draft e-Notification Form designed to address the current lack of uniformity in termination for cause reporting. In developing the form, SILA drew common data points from existing state processes to create a streamlined two-page form. The e-Notification Form would provide notification to every state in which a licensee is either appointed or holds an active license and is being terminated for cause. Among the benefits of the SILA’s proposed e-Notification Form, the form would enable simultaneous notification to all relevant state regulators of any misconduct, disclosure of where business was conducted, and disclosure of any consumer harm and related remediation efforts. SILA’s goal is to deliver notifications within 48 hours of a termination for cause.
Update on the 1033 Template Written Consent Process
PLTF continued discussion of its redesign of the process for waiver requests under 18 U.S.C. § 1033, developed in an effort to make the written consent process more effective and efficient for regulators. 18 U.S.C. § 1033, “The Violent Crime Control and Law Enforcement Act of 1994,” is a federal statute that prohibits the employment in the business of insurance of a person convicted of a felony involving dishonesty or a breach of trust, unless such person has obtained a written waiver of this prohibition from a regulatory official authorized to regulate the insurer.
PLTF adopted the 1033 Template Written Consent Process at the 2025 Summer National Meeting, but the template was referred back to the PLTF after the Market Regulation and Consumer Affairs (D) Committee returned it for further review due to industry concerns about differences in state definitions of “conviction.” As drafted, the template defines “conviction” as including “but not limited to having been found guilty by verdict of a judge or jury, having entered a plea of guilty or nolo contendere or no contest, or having been sentenced to probation, a suspended sentence, or a fine.” A drafting note in the template provides that states should not consider for written consent a person who has successfully completed deferred adjudication and has not been convicted of a qualifying felony, while also noting that states may include in the definition of “conviction” a plea in abeyance, a diversion, a sealed, or an expunged conviction.
Concerns were raised by a trade group that inconsistencies across state definitions of “conviction” could create regulatory uncertainty for individuals seeking to obtain producer licenses in multiple states. Certain problematic scenarios were raised, such as creating compliance risk for insurers with respect to sealed or expunged convictions in states where insurers do not have an ability to access such information or the use by insurers of third-party vendors to conduct background checks that may not appreciate state differences. The trade group asked PLTF to consider issuing guidance on how to reconcile differences in the “conviction” definition and whether the Home State should be given deference on the issue.
The Virginia Bureau of Insurance stated that, beginning on July 1, 2026, it will be implementing legislation that prohibits the Bureau of Insurance from asking questions about or considering sealed records, which could create issues with subsequent non-resident states that do not share the same approach to sealed records. The California Department of Insurance requested that the PLTF retain the template as it was submitted to the Market Regulation and Consumer Affairs (D) Committee at the 2025 Fall National Meeting, including requiring applicants to provide letters and statements from the applicants’ employer or prospective employer only “if applicable,” which accommodates the fact that many 1033 waiver applicants do not yet have an employer or prospective employer in the insurance industry at the time of application. The California Department of Insurance also advocated for retaining reference to nolo contendere or no contest pleas and urged that convictions should be disclosed whether they are “expunged,” “sealed,” “dismissed,” or characterized by some other term, leaving it to each state’s commissioner or director to determine the appropriate weight to give such convictions under their applicable state law. The Nebraska Department of Insurance also asked the PLTF to consider set-asides, where a judge sets aside a conviction.
The PLTF will continue to consider these issues, including by gathering information on how states treat sealed or expunged records, and further discussion is expected at future meetings to determine what changes may be needed to the template to resolve the concerns identified.
Adoption of Working Group Reports
The PLTF then received and adopted reports on the recent activities of its working groups, including the Adjuster Licensing (D) Working Group, Producer Licensing Uniformity (D) Working Group, and the Uniform Education (D) Working Group.
Adjuster Licensing (D) Working Group
The Adjuster Licensing Working Group discussed its 2026 priorities, emphasizing modernization and streamlining of the adjuster Designated Home State (“DHS”) qualifications, individual state producer licensing databases, and growing need for DHS validation as key focus areas. The Working Group identified more than 200 state-specific non-uniform questions (“NUQs”) as a significant source of confusion and inefficiency, noting that many may be outdated or no longer relevant. The Working Group plans to holistically review the NUQs in 2026, prompted by an interest among states in potentially eliminating unnecessary NUQs. The Working Group also discussed interstate coordination to tackle DHS licensing challenges, including the issue of forum shopping among adjuster licensing applicants.
Producer Licensing Uniformity (D) Working Group
The Producer Licensing Uniformity Working Group discussed its comprehensive review of the NAIC State Licensing Handbook. In total, the working group identified 14 of the Handbook’s 30 chapters as warranting revisions, and completed updates to Chapter 1 (Modern Producer Licensing); Chapter 7 (Application Review for Initial Licenses); Chapter 9 (Lines of Insurance), Chapter 10 (Surplus Lines Producer Licenses), and Chapter 11 (Appointments). Several chapters remain on the agenda for 2026, including Chapter 12 (Business Entity), Chapter 13 (Temporary Licenses), Chapter 19 (Bail Bond Agents), Chapter 24 (Managing General Agents), Chapter 25 (Multiple Employer Welfare Arrangements), and Chapter 30 (Viatical Settlement Providers and Brokers). The working group also discussed a potential new chapter addressing pharmacy benefit managers. In addition, the Working Group examined state compliance with the NAIC Uniform Licensing Standards and is in the process of gathering all state charts to determine areas of non-compliance. Finally, the working group has been working on maintaining current licensing contact information for every state.
Uniform Education (D) Working Group
In 2025, the Uniform Education Working Group assisted the Producer Licensing Uniformity Working Group in updating the NAIC State Licensing Handbook and revised Chapters 6 (Prelicensing Education), Chapter 8 (Testing Programs) and Chapter 14 (Continuing Education). In 2026, the Working Group turned its attention to reviewing and updating Appendix C (Course Guidelines for Classroom Webinar/Webcast Delivery) to the NAIC 2019 Continuing Education Reciprocity Agreement. These updates were circulated for public comment, with responses due by March 23, 2026. The Working Group also took up the subject of introductory statement guidelines and course approval letters and is surveying states to determine current practices in those areas. Finally, the Working Group discussed the Standard Instructor Form, with plans to expose the form for review and potentially adopt the form during the Working Group’s April monthly meeting.
Mayer Brown associate Lindsey Gilberg also contributed to the content of this article.
To view additional updates from the US NAIC Spring 2026 National Meeting, visit our meeting highlights page.
