Preventable Filing Delays Cost P&C Insurers $72.8 Million per day, ZestyAI Analysis Finds

A wide-ranging analysis of P&C filings by ZestyAI has found that the regulatory delays costing insurers tens of millions of dollars each day are predictable, compounding, and largely preventable.

Using its regulatory intelligence platform ZORRO Discover, ZestyAI analyzed more than 2 million P&C rate and form filings – representing over 200 million pages – and found that delays are driven primarily by how filings are prepared and submitted, not by the substance of the rate changes regulators are reviewing.

Across lines, objections are not evenly distributed. They cluster around a small number of recurring failure points: submission gaps, missing or inconsistent supporting exhibits, unclear factor rationale, and incomplete responses to regulator inquiries. Many of these issues surface before regulators have begun assessing the merits of the proposed rate change at all.

Quantifying the cost

To estimate the cost of these delays, ZestyAI looked at 147 homeowners’ rate filings approved in Q2–Q3 2025 in “prior-approval” states – jurisdictions where insurers cannot put a new rate into effect until regulators have issued formal approval. Across those filings, the average rate increase that regulators ultimately approved was 8.49%. Applied against $51.7 billion in homeowners’ direct written premium in those states, each day of delay between filing and approval represents roughly $12 million in foregone pricing impact for the industry. Scaled across all P&C lines, the figure rises to an estimated $72.8 million per day.

What makes these operational failures especially costly is how dramatically they extend approval timelines. In a separate analysis of more than 4,492 personal auto rate filings approved over the past year, ZestyAI found that filings receiving no objections were approved in 14 days on average, while filings that received at least one objection took 51 days – more than three times longer.

“Regulatory delay isn’t really about regulators slowing things down – it’s a function of execution,” said Bryan Rehor, Senior Director of Regulatory & Government Affairs at ZestyAI. “Most of what’s triggering objections is mechanical: a missing unity exhibit, the wrong checklist, an unsupported discount factor. Filing and response quality alone can be the difference between a one-month approval and a six-month one.”

“Each objection cycle resets the review clock, expands its scope, and increases the likelihood of further follow-up,” Rehor added. “That’s where technology can help – by enforcing consistency across jurisdictions and filing cycles, without replacing actuarial or regulatory judgment.”

Where filings break down

The analysis points to five recurring failure modes. Drivers vary by state and line of business, but the patterns are consistent:

1. Submission and packaging – incomplete or incorrect checklists, wrong filing type, missing notices. 

Connecticut requires the Actuarial Checklist 12-2020 to be attached and fully completed for rate filings, cited in 70% of personal auto filings objected to.

2. Actuarial support – missing unity exhibits; insufficient loss, trend or expense support; unclear investment income offsets. 

In Washington, expense exhibit and profit calculation gaps under RCW 48 are the #2 driver of commercial filing objections.

3. Rating factors – discounts or surcharges that aren’t supported by data; insufficient factor rationale. 

In Montana, factor rationale issues drive 83% of homeowners’ objections under MCA 33-16-203, which requires data sufficient to substantiate every rating element. 

4. Model transparency – predictive models not fully filed; incomplete diagnostics or documentation; unclear linkage to rate impact. 

In Florida, the Office of Insurance Regulation asks carriers about wind-loss modeling and Ex-Wind Credit exhibits, appearing in 74% of objected homeowners filings.

5. Catastrophe assumptions – CAT loads or trends questioned; unclear reinsurance treatment. 

In New Jersey, hurricane catastrophe model methodology and reinsurance cost allocation under ASOP 38 drive 52% of objected homeowners’ filings.

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