Please take note of the following December 2025 developments in the insurance industry.

  • NAIC Elections: On December 11, 2025, the National Association of Insurance Commissioners (NAIC) elected the following chief state insurance regulators to serve as officers in 2026, effective January 1, 2026.
    • President: Virginia Insurance Commissioner Scott A. White.
    • President-Elect: Rhode Island Department of Business Regulation Director Elizabeth (Beth) Kelleher Dwyer.
    • Vice President: Utah Insurance Department Commissioner Jon Pike.
    • Secretary-Treasurer: South Carolina Department of Insurance Director Michael Wise.

      The NAIC also elected the following zone leadership:
    • Northeast Zone
      • Chair: Commissioner Justin Zimmerman (New Jersey)
      • Vice Chair: Commissioner D.J. Bettencourt (New Hampshire)
      • Secretary: Commissioner Marie Grant (Maryland)
    • Southeast Zone
      • Chair: Commissioner Mike Chaney (Mississippi)
      • Vice Chair: Commissioner John King (Georgia)
      • Secretary: Commissioner Michael Yaworsky (Florida)
    • Midwest Zone
      • Chair: Director Eric Dunning (Nebraska)
      • Vice Chair: Director Larry D. Deiter (South Dakota)
      • Secretary: Director Ann Gillespie (Illinois)
    • Western Zone
      • Chair: Commissioner Ricardo Lara (California)
      • Vice Chair: Commissioner Patty Kuderer (Washington)
      • Secretary: Commissioner Ned Gaines (Nevada
  • Hawaii AI Guidance: On December 10, 2025, Hawaii issued Memorandum 2025-13A, adopting the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, making it the 25th state to do so.
  • Massachusetts Proposed PBM Regulation: On December 4, 2025, Massachusetts issued for public comment a proposed regulation regarding pharmacy benefit managers (PBMs), 211 CMR 157.00, Licensing and Regulation of Pharmacy Benefit Managers. On January 8, 2026, Massachusetts will hold a public hearing at 10 a.m. to hear comments. The purpose of this regulation is to implement and outline the requirements for licensing and regulating PBMs pursuant to M.G.L. c. 176Y. “No Person, business, or other entity shall establish or operate as a Pharmacy Benefit Manager (PBM), perform the functions of a PBM, or provide Pharmacy Benefit Management Services without obtaining a license from the Division in accordance with the provisions of 211 CMR 157.00.”
  • Oregon Insurance Commissioner Announcement: On December 3, 2025, the Oregon Department of Consumer and Business Services (DCBS) announced that TK Keen is the Oregon insurance commissioner. Keen has been serving in the acting insurance commissioner role since June and was deputy insurance commissioner for five years before that. He is also the administrator of the Oregon Division of Financial Regulation (DFR), part of DCBS.
  • New Jersey Department of Banking and Insurance Adopts Bulletin No. 24-16 Capping Copays for Certain Prescription Drugs in Department-Regulated Health Insurance: On December 2, 2025, the New Jersey Department of Banking and Insurance adopted Bulletin No. 24-16 outlining requirements for state-regulated insurers to cap certain out-of-pocket costs on critical prescription medications. The purpose of the bulletin is to provide guidance to hospital, medical, and health service corporations, insurance companies, and health maintenance organizations authorized to issue health benefits plans in New Jersey concerning two recently enacted statutes, P.L. 2023, c. 275, concerning the coverage of hearing aids and cochlear implants, and P.L. 2023, c. 105, concerning cost sharing for the treatment of diabetes, epinephrine auto-injector devices, and prescription asthma inhalers.
  • Alaska SB132 Implementation and General Licensing Guidance: On December 2, 2025, Alaska issued Bulletin B25-09 providing guidance on PBMs, third-party administrators, independent adjusters, designated home states, and other relevant national uniformity updates related to Alaska Senate Bill (SB) 132, the Omnibus Insurance Bill, which becomes effective on January 1, 2026.