Oregon is strengthening how it oversees insurance holding companies.
With the passage of Senate Bill 831 during the 2025 legislative session, state lawmakers have expanded regulatory requirements for insurers that are part of holding company systems. The new provisions, which become operative on January 1, 2026, revise five key sections of Oregon Revised Statutes—ORS 732.548, 732.553, 732.569, 732.574 and 732.586—and bring Oregon in closer alignment with national supervisory models.
The legislation requires registered insurance holding companies to file an annual group capital calculation and, under specific conditions, conduct liquidity stress tests using the NAIC Liquidity Stress Test Framework. These additions mean insurers must report on enterprise risks and their potential impact on financial condition and liquidity—not just within the insurer, but across affiliated entities.
Under SB831, a group capital calculation must be submitted unless a company qualifies for one of four specific exemptions—such as writing insurance only within the domestic state or already submitting calculations to the Federal Reserve Board. Even foreign-based holding systems are not automatically exempt; the bill permits Oregon’s chief insurance regulator to require a U.S.-specific group capital calculation if necessary for oversight or market stability.
Insurers meeting scope criteria for a given data year under the NAIC framework are also required to conduct and file results from a liquidity stress test, unless otherwise exempted by the state’s chief insurance regulatory official. These scope criteria include quantitative thresholds and apply to insurers that meet at least one designated condition.
The bill also introduces stronger provisions around affiliate data control and access. It specifies that all insurer records held by affiliates—including claims, premiums, and underwriting data—remain the property of the insurer and must be clearly segregated. Affiliates are required to grant access to these records and supporting systems if the insurer enters receivership.
On the transactional side, SB831 sets notification thresholds for inter-affiliate transactions. These include deals such as loans, investments, guarantees, and cost-sharing agreements. Transactions that exceed 3% of admitted assets or 25% of surplus, depending on the insurer’s line of business, must be disclosed to the Department of Consumer and Business Services in advance. Reinsurance deals that impact 5% or more of an insurer’s surplus are also subject to the same rules.
Additional language strengthens the regulator’s discretion. If the director of the Department of Consumer and Business Services determines that an insurer is in a hazardous condition, they may require the company to secure a bond or deposit as a condition of continuing operations.
Confidentiality provisions are also expanded. Group capital ratios, liquidity stress test results, and related disclosures are not to be made public, and may not be used in marketing or investor materials, except to rebut demonstrably false statements.
The law takes effect 91 days after the close of the 2025 regular legislative session, giving companies limited time to prepare for a regulatory shift that could have nationwide implications for multi-state insurers.
