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Insurance industry urges CPPA to defer insurance‑specific privacy rules until NAIC completes model law
Summary
APCIA and insurance‑sector speakers told the CPPA on Feb. 19 to pause the proposed insurance regulations pending the National Association of Insurance Commissioners' model law work; they warned of duplication and urged coordination with Department of Insurance
SACRAMENTO, Feb. 19, 2025 — Representatives of the property‑casualty insurance industry told the California Privacy Protection Agency at a Feb. 19 public hearing that the agency should pause finalizing insurance‑specific privacy regulations until the National Association of Insurance Commissioners (NAIC) completes revisions to its privacy model law.
Why it matters: Insurance companies argued they already operate under comprehensive privacy and security obligations and that overlapping or conflicting state regulations could create uncertainty for consumers and industry.
APCIA request and rationale
Laura Curtis, representing the American Property Casualty Insurance Association (APCIA), asked the CPPA to refrain from finalizing its insurance regulations "until the NAIC has completed its work on the new privacy model law and California has adopted the law and then reassess whether regulations are needed." APCIA said federal and state insurance‑specific privacy work, including the NAIC model law, could provide greater clarity and avoid duplication.
Industry concerns
APCIA and other commenters said the proposed insurance regulations risk introducing inconsistent or duplicative obligations on automated decision‑making, cybersecurity audits and risk assessments, and urged close coordination with the California Department of Insurance.
Next steps
The CPPA will review written and oral comments. APCIA said it had submitted more detailed written comments and asked the agency to work with state and national regulators before proceeding.
Ending: The hearing concluded with staff noting the comment period closed Feb. 19 and that the agency will respond to comments in the final statement of reasons required by the Administrative Procedures Act.
