ZestyAI Reckon Regulatory Delays Are Costing Insurers

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.

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.”