New York is the third-largest property and casualty insurance market in the country. It is also one of the most complex regulatory environments any admitted carrier will encounter. The New York Department of Financial Services (DFS), the agency that oversees insurance alongside banking and financial services regulation, administers a multi-layered reporting framework that touches nearly every admitted New York P&C insurer writing business in the state.
Unlike some states where statistical reporting is channeled through a single bureau or agent, New York’s obligations are distributed across multiple statutory and regulatory instruments, each with its own filing cadence, submission platform, and enforcement mechanism. The practical consequence for carriers: compliance requires coordinating data across policy administration, claims, underwriting, and finance on timelines ranging from seven days to annually, with no single checklist that covers every scenario.
This guide is written for compliance officers, actuaries, technology leaders, and operations professionals who need a working understanding of what New York requires, who must file, and what the compliance stakes look like. It is also a framework for thinking about what kind of policy administration infrastructure makes that compliance operationally sustainable.
Why New York’s Reporting Framework is Different
Most states delegate statistical reporting to a designated bureau such as ISO, NCCI, or a state-specific equivalent like TICO in Texas or POIDRS in Louisiana. New York operates differently. The DFS collects a significant portion of its market intelligence directly from carriers, using its broad authority under Section 308 of the New York Insurance Law to compel special reports on virtually any subject the Superintendent determines is necessary to regulate the industry.
This direct-collection model means that New York’s reporting landscape is fragmented by design. There is no single “New York statistical plan” that covers all lines. Instead, carriers encounter a matrix of obligations: some triggered by premium thresholds, some universal, some line-specific, and some issued on an ad hoc basis through formal data calls. Managing this matrix without structured data infrastructure is a recurring source of compliance exposure.
What makes this especially consequential is the DFS’s enforcement posture. The agency has demonstrated a clear willingness to take formal action, including consent orders and material fines, against carriers that fail to file on time, file inaccurately, or maintain inadequate systems for tracking compliance obligations. In 2025, DFS secured 37 consent orders against auto insurers and collected approximately $20 million in aggregate penalties, primarily related to IIES reporting failures. This is not a hypothetical compliance risk. It is a recurring operational one.
The New York P&C Insurance Reporting Landscape: An Overview
The table below summarizes the primary ongoing reporting obligations for admitted P&C insurers in New York. This is not an exhaustive list (the DFS issues ad hoc data calls throughout the year under Section 308 authority) but it covers the core statutory and regulatory reporting requirements that carriers must build into their operational calendars.
| Report | Line of Business | Authority | Frequency / Due Date | Who Must File |
| Regulation 154 Quarterly Report | Homeowners Multiple Peril | 11 NYCRR 19 (Reg 154) | Quarterly — 30 days after quarter close | Carriers with ≥$500K NY DWP in prior year |
| Section 3425 Compliance Report (2% Report) | Private Passenger Auto | NY Ins. Law §3425(l)(1) | Annually — April 30 | All licensed P/C carriers writing PPA |
| Regulation 90 / Anti-Redlining Annual Report | PPA, Fire, Fire & Extended Coverage | 11 NYCRR 218 (Reg 90) | Annually — May 1 | Carriers with >$500K NY DWP in covered lines |
| Medical Malpractice §315 Quarterly Report | Medical Malpractice | NY Ins. Law §315 | Quarterly — 1 month after quarter close | All admitted carriers writing med-mal directly |
| Annual Availability Survey + Coastal Supplement | All P/C Lines | NY Ins. Law §308 | Annually — December 31 | All licensed P/C carriers |
| Public Auto Classifications Data Call | Public/Commercial Auto | NY Ins. Law §308 | Annually — June 20 | Carriers writing public auto business |
| Private Passenger Auto Data Call | Private Passenger Auto | NY Ins. Law §337 | Annually — April 30 | Selected carriers (DFS invitation) |
| IIES — Insurance Information & Enforcement System | Private Passenger & Commercial Auto | 15 NYCRR Part 34 / Art. 6 | Within 7 days (new); 30 days (terminations) | All auto insurers writing NY-registered vehicles |
| Fraud Prevention Plan + Annual SIU Report | PPA (≥3,000 policies) | NY Ins. Law §308 / Reg 195 | Annual SIU report + plan updates as required | P/C carriers writing PPA with 3,000+ policies |
| New York Annual Statement + NY Supplement | All Lines | NY Ins. Law §307 / NAIC | Annually — March 1 | All authorized NY insurers |
Key New York Insurance Reporting Requirements in Depth
IIES: The Auto Insurance Reporting Obligation With Real Teeth
The Insurance Information and Enforcement System (IIES) is operated jointly by the DFS and the New York Department of Motor Vehicles. Under Article 6 of the Vehicle and Traffic Law and 15 NYCRR Part 34, every insurer providing coverage on a New York-registered motor vehicle is required to report new policies to DMV within seven days of the policy’s effective date. Terminations, cancellations, and suspensions must be reported within 30 days, and for-hire vehicles must be reported at least 20 days prior to the termination effective date.
IIES is not optional for any admitted auto carrier. It applies to private passenger, commercial, and fleet vehicle policies on registered New York vehicles. The system is designed to enable law enforcement identification of uninsured vehicles and to maintain the integrity of New York’s financial responsibility requirements.
The compliance risk here is structural. The DFS’s 2025 enforcement actions were driven by persistent late reporting in 2018 and 2019. The core problem identified was not willful non-compliance but inadequate data systems: carriers unable to produce timely IIES submissions because their policy administration platforms did not support automated, real-time reporting to DMV. The DFS made clear that the complexity of the underlying system does not excuse the reporting failure.
Carriers using the current IIES system, which is desktop-software-based and email-submitted, not a modern online portal, should be actively assessing whether their current workflows can sustain the seven-day and thirty-day deadlines at scale. This is particularly acute for carriers managing high transaction volumes or operating through MGA structures where policy issuance is distributed across multiple entities.
Regulation 154: Quarterly Homeowners Market Monitoring
11 NYCRR 19 (Regulation 154) requires licensed P&C carriers with $500,000 or more of New York Direct Written Premium in homeowners multiple peril insurance in the prior calendar year to file quarterly reports with the DFS. These reports are due within 30 days of the close of each calendar quarter and must now be submitted through the DFS Portal.
The purpose of Regulation 154 is market monitoring specifically to allow the DFS to assess whether carriers are maintaining adequate homeowners market participation across defined areas of the state, including coastal regions. The reporting feeds the Superintendent’s study of homeowners “market dynamics” and informs analysis of availability in areas where the New York Property Insurance Underwriting Association (NYPIUA), the state’s residual market mechanism, has seen elevated activity.
The quarterly cadence and premium threshold mean that carriers need to monitor their New York homeowners DWP annually to determine whether they are in scope for the following year’s filing obligation. A carrier that crosses $500,000 in a given year must file all four quarters of the following year. There is no mid-year entry or partial-year exemption.
The DFS also requires a Special Homeowners Insurance Coastal Supplement as part of the Annual Availability Survey. Carriers writing homeowners business along New York’s coastline, including Long Island, the boroughs of New York City, and the Hudson Valley, should expect the coastal supplement to require granular data on insured values, coverage terms, and coastal exposure by territory.
Section 3425 Compliance Report: The 2% Report
New York Insurance Law Section 3425(l)(1) requires every licensed P&C carrier writing private passenger automobile insurance to file an annual compliance report (informally known as the “2% Report“) due April 30 of each year. The report captures data on rating territories, primary driver classifications, new insureds written during the year, and non-renewals.
The 2% Report is used by the DFS to prepare a report to the Governor and Legislature on the state of the private passenger auto market. It also serves as a compliance monitoring tool for Section 3425 itself, which restricts non-renewals and certain cancellations in the private passenger auto line and imposes procedural requirements around notice and explanation.
An important structural nuance: carriers with multiple rating programs approved under Section 2352 of the Insurance Law must file a separate 2% Report for each program. These are not multi-tier programs under Section 2349 and 11 NYCRR 154, which are addressed under a separate tab in the reporting form. Carriers with complex personal auto programs should audit their Section 2352 approvals before each filing cycle to ensure they are not inadvertently omitting a required submission.
Regulation 90: Anti-Redlining Annual Reporting
11 NYCRR 218 (Regulation 90), implemented pursuant to Circular Letter No. 17 (1996), requires annual reporting from licensed P&C carriers that wrote more than $500,000 of New York Direct Written Premium in private passenger automobile, fire, or fire and extended coverage insurance during the prior calendar year. The report is due May 1.
The purpose of Regulation 90 is to provide the DFS with the data it needs to enforce New York’s prohibition on geographical redlining in personal lines insurance. “Redlining” in the regulatory sense refers to the unlawful practice of declining to write or limiting the availability of coverage in specific geographic areas based on the demographic composition of those areas, rather than actuarially justified risk characteristics.
The annual report captures territory-level data on policies written, premiums, and declinations as this is the data pattern that would signal a geographic withdrawal or restriction inconsistent with legitimate underwriting. Carriers that have been active in markets subject to redlining scrutiny, particularly in New York City and its surrounding areas, should treat the Regulation 90 submission as a compliance document, not a routine administrative filing.
Section 308 Data Calls: The Superintendent’s Residual Authority
Section 308 of the New York Insurance Law gives the Superintendent broad authority to require any licensed insurer to provide special reports on any matter within the DFS’s jurisdiction. This authority is the basis for several of the recurring annual data calls, including the Annual Insurance Availability Survey, the Public Auto Classifications data call, the Medical Malpractice Insurance Plan data call, and the Private Passenger Auto data call.
The Annual Availability Survey is the most broadly applicable of these, required of all licensed P&C insurers. It encompasses the Free Trade Zone report (for carriers writing in the New York Free Trade Zone under Regulation 86) and the Special Homeowners Insurance Coastal Supplement. The survey is due December 31 each year and is used to assess market capacity across difficult-to-place lines and geographic areas.
Section 308 data calls are issued by the DFS with specific instructions and deadlines, sometimes on short notice. Carriers that do not actively monitor DFS communications, through the agency’s weekly bulletins, portal notifications, and industry guidance, risk missing a call they are required to respond to. This is a genuine compliance gap for carriers that treat DFS correspondence as low-priority operational mail.
The New York Annual Statement and Supplement
Every insurer authorized to write insurance in New York must file an Annual Statement with the DFS by March 1 each year, pursuant to Section 307 of the Insurance Law. New York requires a state-specific supplement beyond the NAIC standard Annual Statement, with additional schedules and exhibits reflecting New York-specific regulatory priorities.
For P&C carriers, the New York Supplement includes Schedule F (a listing of all property insurance companies authorized in New York as of December 31 of the prior year) and related addenda. The Annual Statement and NY Supplement filing instructions are updated annually and published on the DFS website; carriers should not rely on prior-year instructions without verifying that no material changes have been made.
The relationship between the Annual Statement and other DFS filings is not incidental. DFS examiners routinely cross-reference Annual Statement data against Section 308 data calls, Regulation 154 quarterly reports, and IIES records. Discrepancies between these filings are a common trigger for targeted market conduct examinations and special report requests. Reconciliation across reporting streams goes beyond being a year-end project and becomes an ongoing data quality requirement.
What New York’s Insurance Reporting Framework Demands from Policy Administration Software
New York’s reporting requirements are not a compliance checklist to be managed in a spreadsheet. They are a structural stress test on the quality of a carrier’s data architecture. The breadth of obligations across lines, the varying cadences, the multiple submission platforms, and the DFS’s demonstrated willingness to take enforcement action create an environment where manual, ad hoc compliance processes carry real organizational risk.
A modern policy administration platform that is purpose-built for the granularity New York demands should be able to do several things that legacy systems typically cannot:
- Capture geographic identifiers at the policy level (territory, ZIP code, county, and coastal designation) at the point of issuance, not through downstream lookup or manual supplementation.
- Maintain real-time policy counts, written premium, and transaction logs by line of business and classification, enabling Regulation 154, Section 3425, and Regulation 90 submissions to be generated from core system data rather than extract-and-reconcile processes.
- Support automated or near-automated IIES reporting workflows, including transaction-level tracking of new policies and terminations against the seven-day and thirty-day filing deadlines.
- Integrate claims data directly with policy records, ensuring that both sides of the statistical equation, premium and losses, are reconcilable from the same underlying data source.
- Generate configurable compliance reports and dashboards that surface the data needed for each specific DFS obligation, rather than requiring custom report builds for every filing cycle.
The carriers that handle New York’s reporting environment with the least friction are those that have made the investment in a data infrastructure where compliance reporting is a byproduct of normal operations. When territory codes are embedded at issuance, when cancellations are logged in real time, and when claims data is linked at the policy level, the DFS filings largely produce themselves. The carriers that struggle are those where data has to be hunted, manually coded, or reconciled after the fact.
Best Practices for New York Insurance Reporting Compliance
Based on the structure of New York’s reporting obligations, carriers operating effectively in this market tend to share several operational characteristics:
1. Build a unified regulatory calendar. New York’s obligations span weekly (IIES), monthly, quarterly, and annual cadences. A compliance calendar that maps every obligation to its due date, responsible owner, and data source, with automated alerts at meaningful lead times, is not optional. It is the minimum infrastructure for a market this complex.
2. Monitor DFS communications actively. Section 308 data calls are issued throughout the year and can carry short response windows. DFS weekly bulletins, portal notifications, and the agency’s industry guidance page are the authoritative channels. A process for reviewing and acting on DFS communications should exist at the compliance function level, not just at the executive level.
3. Reconcile across filings proactively. The DFS cross-references Annual Statement data against Regulation 154, Section 3425, IIES, and other submissions. Reconciliation between reporting streams should happen on a rolling basis, ideally within the core system, not as a pre-submission scramble.
4. Audit your threshold exposures annually. Several New York obligations are triggered by prior-year premium thresholds (Regulation 154 at $500,000 for homeowners; Regulation 90 at $500,000 for PPA/fire). As premium grows or market mix shifts, new obligations can materialize without obvious triggers. An annual review of DWP by line and geography against obligation thresholds is a straightforward way to identify new exposures before a filing deadline reveals them.
5. Treat IIES as a real-time operations requirement. The seven-day new-policy reporting requirement and thirty-day termination requirement are not statistical reporting in the traditional sense. They are transaction-level compliance obligations tied directly to policy issuance and cancellation workflows. Systems that cannot generate IIES-compliant data at the point of transaction — rather than in a periodic batch — are structurally exposed.
About WaterStreet
WaterStreet Company’s cloud-based policy administration platform is designed for the data precision that complex regulatory environments like New York demand. Policy transactions capture geographic, classification, and coverage-level data at the point of issuance — not through downstream processing — which means the underlying data for Regulation 154, Section 3425, Regulation 90, and IIES reporting is always current, structured, and accessible.
Built-in Business Intelligence capabilities give compliance, actuarial, and operations teams real-time visibility into the data behind every DFS filing obligation — so that the Annual Statement reconciles cleanly against quarterly reports, and every data call is answered from the core system rather than a manual extract project.
For carriers operating in New York or evaluating market entry, WaterStreet provides the policy administration infrastructure to meet the state’s reporting demands operationally, not as a compliance exercise that runs parallel to the business, but as an output of how the business runs.
To learn more about how WaterStreet supports New York carriers navigating reporting requirements, visit waterstreetcompany.com.
Reach out to WaterStreet Company today to request a consultation and demo.
Sources:
New York Insurance Law §307 — Annual Statement filing requirements
New York Insurance Law §308 — Superintendent’s authority to compel special reports
New York Insurance Law §315 — Medical malpractice quarterly reporting
New York Insurance Law §3425 — Personal lines cancellation and nonrenewal; 2% Compliance Report
11 NYCRR 19 (Regulation 154) — Homeowners quarterly reporting requirements
11 NYCRR 218 (Regulation 90) — Prohibition of geographical redlining; annual reporting
15 NYCRR Part 34 — IIES reporting requirements for auto insurers
NY DFS — Property/Casualty Data Calls and Reporting Requirements: https://www.dfs.ny.gov/apps_and_licensing/property_insurers/property_data_calls
NY DFS — Annual Statements and New York Supplement Filing Requirements: https://www.dfs.ny.gov/apps_and_licensing/insurance_companies/annual_statements_ny_supplements
NY DFS — Insurance Information and Enforcement System (IIES): https://www.dfs.ny.gov/apps_and_licensing/property_insurers/iies_system
