California insurers can now have the Department of Insurance (CDI) review a proposed rate change before they formally file it. If they then file a qualifying application, they get a faster, more predictable approval process. The new Comprehensiveness Review regulation, announced by Insurance Commissioner Ricardo Lara on October 19, 2026, applies to personal and commercial lines rate changes. Under it, the department’s view of the permissible rate range, and the full record of the review, will be available for public inspection.
According to the final regulation and filing documents, the rule (CDI file REG-2025-00024) adopts new sections 2644.29 and 2648.2.2 and amends sections 2648.2 and 2648.4 of Title 10 of the California Code of Regulations. The Office of Administrative Law (OAL) accepted it as a “file and print” action, and it was filed with the Secretary of State and took effect on October 15, 2026. OAL’s notice states that the action is exempt from the Administrative Procedure Act under Government Code § 11340.9, subdivision (g). OAL was therefore asked only to file and publish it, not to review it under the act’s usual rulemaking standards.
Under Proposition 103, codified at Insurance Code § 1861.05, most property and casualty rate changes must be approved by the commissioner before use. The new section 2644.29 creates an optional step in front of that process. An insurer begins a comprehensiveness review by giving CDI’s Rate Regulation Branch everything it believes the commissioner would require for a complete rate application. An insurer may start a review for any one line of insurance no more than once every 180 days, though it can run reviews on different lines at the same time.
The branch first decides whether the submittal is sufficient to analyze. If it is, the branch issues an “affirmative evaluation of sufficiency” setting the maximum and minimum earned premium that would be permissible if the submittal were filed as a formal application. That range is the rate indication CDI’s announcement referred to. The branch must generally issue it within 90 days of the review’s start. The insurer then has 10 days to either revise its submittal to a rate within the range or withdraw. If the revised submittal contains everything needed for approval, the branch issues an “affirmative evaluation of comprehensiveness,” generally within 17 days. If something is missing, the branch issues one request for clarification, and the review ends if the insurer’s cure falls short. The branch may extend these deadlines by up to 60 days in total, in increments of no more than 30 days, with a written explanation of the deficiencies.
All submittals, determinations, requests, and other communications must be made through the industry’s electronic filing system, SERFF. The regulation provides that all information given to the department during a review is available for public inspection through SERFF. In its announcement, CDI said it would also publicly release the rate savings its staff projects, which it called unprecedented. Lara said in the release that “every dollar Californians pay for insurance should be justified.”
The payoff for insurers comes in new section 2648.2.2. An insurer that receives an affirmative evaluation of comprehensiveness, and files a formal application within 16 days that simply incorporates its reviewed submittal, gets an “inference of comprehensiveness.” The department’s usual 30-day completeness review under section 2648.2 is skipped. Public notice must issue within 10 days of filing, and the application must be approved no sooner than 47 days and no later than 60 days after notice. The 60-day deadline does not apply if a timely petition for a hearing is filed and either the commissioner grants it or the requested change exceeds 7 percent for personal lines or 15 percent for commercial lines. Those thresholds mirror the statutory triggers for a hearing on request under § 1861.05(c). The inference can be lost if facts unknown to CDI staff later show the submittal was incomplete.
Several categories are excluded. A submittal may not include specialty insurance rates, auto class plan revisions, or models used for segmentation, underwriting, or risk scoring. Catastrophe models projecting aggregate losses are allowed only when the model already has a valid pre-application determination under section 2648.5 or is used solely for earthquake, fire following earthquake, flood, or terrorism coverage. The commissioner may reject a submittal if the insurer has a formal application pending on the same line, if it contains an excluded item, or for good cause.
The regulation’s treatment of public participation differs somewhat from CDI’s framing. The department’s announcement said the regulation continues the intervenor process, under which consumer representatives may challenge rate requests and seek compensation under Insurance Code § 1861.10. The text of section 2644.29, however, states that a comprehensiveness review is not a “proceeding” for any purpose under Proposition 103. It also provides that CDI’s intervenor participation and compensation rules do not apply to the review itself. Intervenors can still petition for a hearing once a formal application is noticed, but the pre-filing review, where the rate range is set, takes place without them. CDI contrasts the public rate indications with intervenor negotiations it says previously occurred behind closed doors.
That distinction may draw attention given recent history. CDI’s separate intervenor regulation, in effect since August 2026, tightened standards for intervenor participation and compensation. Consumer Watchdog and a coalition of consumer groups opposed that rule. As of this writing, we found no public statement from consumer groups or insurer trade associations on the comprehensiveness review. Insurance Journal reported that the American Property Casualty Insurance Association had been contacted for comment.
The rule also tightens the department’s existing Complete Rate Application requirements, first proposed in 2024. Under the amendments to sections 2648.2 and 2648.4, an application is not complete, and the statutory review clock does not start, until the insurer also delivers “reconciled data.” That data must be reconciled consistently with applicable Actuarial Standards of Practice. The change builds on the data reconciliation tool CDI introduced in its August 2024 Bulletin 2024-7. The regulation is part of Lara’s Sustainable Insurance Strategy. CDI cites as authority Insurance Code sections 1861.01 and 1861.07 and 20th Century Ins. Co. v. Garamendi (1994) 8 Cal.4th 216.
For carriers, including those writing commercial coverage for employers, the trade-off is speed and certainty against early public disclosure. A carrier that accepts CDI’s range up front can expect approval within a fixed window. In exchange, the department’s view of its rate need, and how far it differs from the carrier’s original request, becomes part of the public record.
This summary is for general informational purposes only; readers should consult the full regulation text and CDI’s statement of reasons for complete details.