This Q&A is intended for auto insurance experts in pricing, underwriting, operations and communications across the industry to address common questions they may have.
As new questions arise, they will be added to this list and flagged with an identifier (*).
Updated as of February 12, 2026.
Questions and answers
*If a customer qualifies for multiple limits for the same Accident Benefits coverage (e.g., $400 under their own policy and $1,000 under their spouse’s policy for income replacement), which limit applies when they make a claim?
FSRA expects insurers to treat customers fairly and in accordance with their rights under the OPCF 47R, ensuring that customers receive the level of coverage available to them under the policy for which they are eligible and under which they have elected to claim benefits.
*Can an OPCF 47R endorsement be added more than once to the same policy when there are multiple vehicles?
The OPCF 47R is a policy‑level endorsement, but it provides flexibility for insurers to include vehicle‑specific information (such as vehicle IDs) when appropriate. Insurers should assess how applying the endorsement across multiple vehicles aligns with their rating rules, underwriting guidelines, and operational processes. Different insurers may take different approaches depending on their system design and product structure.
FSRA allows flexibility in how insurers implement the OPCF 47R, provided that:
- customers are treated fairly
- the insurer’s approach is transparent
- customers have access to the highest level of coverage available to them under the policy for which they are eligible and under which they have elected to claim benefits
*Do the changes taking effect on July 1, 2026, apply to all customers, or only to new business?
The changes effective July 1, 2026, apply to all customers.
As of this date, all Accident Benefits, except medical, rehabilitation, and attendant care benefits will become optional.
Optional accident benefits only apply to:
- the named insured
- the spouse of the named insured
- dependants of the named insured and of the named insured’s spouse
- persons listed as drivers of the insured automobile
Insurers are encouraged to ensure that all drivers are listed on the vehicle/policy to support clarity and transparency.
*Do insurers need to add OPCF 47R as of July 1st, 2026, for all existing business?
No. On July 1, 2026, FSRA does not require insurers to add the OPCF 47R immediately to any policy effective before July 1, 2026. For these policies, the endorsement is added to reflect midterm changes to Optional Accident Benefits prior to renewal or when the policy renews.
*What is the expectation for customer communications prior to the July 1, 2026, changes taking effect?
Insurers and their intermediaries must communicate with customers in a clear, transparent, and fair manner to build awareness of the upcoming July 1, 2026, Accident Benefits changes. Because the reforms apply to all customers as of July 1, 2026, existing policyholders may wish to review or adjust their Accident Benefits selections before their renewal date. Early communication helps ensure customers understand their options and can make informed decisions. Insurers are encouraged to use efficient and cost‑effective methods such as digital channels, coordinated messaging with distributors, and other proactive outreach. These communications should supplement, not replace, the reform information included in the policy renewal package.
Will FSRA reject an insurer’s filing if they decide not to offer each coverage individually?
No. Referring to the communication from FSRA dated November 28, 2024, offering each of the nine new optional coverages individually is a preferred or ‘supported practice’. Insurers should decide which coverages they want to offer individually or through bundles based on their understanding of consumer needs while delivering on the promise of more choice for consumers. For example, bundling coverages together that have a very low technical cost may make sense for insurers and consumers.
Can an insurer only offer bundles?
If it’s clear that bundles align with consumer needs and offer sufficient choice, FSRA will allow it. Customers must be able to decline higher cost coverages irrespective of the insurer’s bundle options. If an insurer proposes only one bundle—for example, all nine coverages offered as a bundle—this does not deliver on the policy intent to offer more choice.
Will FSRA or the government be giving more direction to insurers on bundles?
No. Insurers may decide to bundle certain related coverages together to create a more simplified offer for consumers or offer bundled savings. FSRA expects that bundles will vary between insurers. New coverage bundles and limits should be based on evidence of consumer needs.
Can an insurer file for different coverage limits?
Yes, insurers may file for new or additional coverage limits. If an insurer wants to begin offering lower or higher limits they may file accordingly. However, existing policies must be renewed with the same coverages and limits as the expiring policy unless the customer agrees to a change in writing.
Do insurers have to offer existing coverage limits to new business?
In the accelerated filing path, yes, you are required to offer all existing limits to new business. In the non-accelerated filing path, insurers need to provide a rationale and supporting evidence for changes to existing limits for FSRA’s consideration.
If insurers introduce a dollar limit for coverages that currently have no specified limit (e.g., visitors’ expenses, personal items), does this disqualify them from using the accelerated filing path?
As of July 1, 2026, coverages such as Expenses of Visitors and Damage to Personal items are to be provided for “reasonable and necessary” expenses up to the defined maximum. Insurers may describe this limit as "unlimited", "no limit", or "all reasonable expenses", etc.
The benchmark costing analysis was based on an unlimited amount being treated as a fixed limit. Therefore, insurers who maintain this approach, by using any of the terms above, remain eligible for the accelerated filing path. However, insurers who propose a specific dollar limit must provide actuarial or other supporting evidence for that limit and must pursue the non-accelerated filing path.
Can an insurer file for lower limits than current ones? Example, income replacement of $300/week.
Insurers have the flexibility to offer various benefit limits if the options are supported with evidence of consumer need provided that current limits are offered.
Can insurers/agents/brokers recommend optional AB coverage when quoting new business?
For new business, insurers may quote as appropriate including both mandatory and recommended optional coverages or bundles. New business processes should be transparent for the customer:
- it should be clear which coverages are optional on the quote/offer
- if transacting digitally, consider ways of making it easy for the customer to add/remove optional coverages without necessarily speaking with an agent or broker
- the premium for each optional coverage or bundle should be clear on the quote
- each optional coverage should be briefly explained in plain language such that the customer can assess whether they need that coverage
- if customers are unsure whether they need an optional coverage, support should be available to help them make a reasonable choice based on their profile
- whether a coverage is recommended or not on the quote/offer page, customers should be aware of all the available optional coverages and limits offered by the insurer
Can an insurer implement a time limit on how long customers can continue renewing on pre-July 2026 coverages and limits before transitioning to post July 2026 offerings?
There is no time limit. Expiring policies must renew with pre-July 2026 coverages and limits until the consumer agrees to make changes in writing as per SABS regulation.
Can an existing customer buy-back to pre-2026 coverages and limits if they had opted out?
If a renewing customer chooses to opt out, they will be subject to the post-July 2026 coverages, limits, and bundles available.
Can we bundle new optional coverages with the current optional coverages, or is it only for the new optional coverages?
Insurers have the flexibility to bundle coverages based on evidence of consumer need. Rates and rules for bundles will need to be filed for FSRA’s review and approval.
Should the optional accident benefits and the applicable bundles be offered at a policy or risk level?
Insurers may wish to consider their current rate & risk classification to decide what is appropriate for them and file accordingly.
What is the expectation when completing vehicle additions or substitutions after July 1, 2026, on policies that have not yet renewed? Are these policy changes subject to accident benefit optionality or existing coverage options and limits until renewal?
SABS optionality should be available to all customers starting July 1st, 2026. If a customer requests options before their renewal date (including at the time of vehicle additions or substitutions), a process must be in place to provide optionality. FSRA will not dictate how you should manage this. You can work within your systems and operational constraints provided you remain transparent and fair to your customers.
In addition to offering caregiver benefit and housekeeping and home maintenance benefit on “an impairment” basis (catastrophic and non-catastrophic), can an insurer offer catastrophic only coverage for new business?
Yes, in addition to offering “an impairment” as required per the SABS regulation, an insurer can offer catastrophic only coverage for caregiver benefit and housekeeping and home maintenance benefit in alignment with s. 28 (1.1) of the SABS.
*What changes are being made to Caregiver and Housekeeping and Home Maintenance benefits as of July 1, 2026?
There are several changes applicable to caregiver and housekeeping and home maintenance benefits as of July 1, 2026. Please refer to the summary below:
Prior to July 1, 2026 On or after July 1, 2026 - mandatory
- optional
- catastrophic impairment with prescribed limits is the standard coverage
- all Impairments is the legislated standard with no prescribed limits
- non-catastrophic impairment with prescribed limits is an optional buy-up
- for new business, insurers may offer a “catastrophic impairment only” buy-down, if filed and approved
The definitions of an “impairment” and “catastrophic impairment” are not affected by the July 1, 2026, changes (please refer to the SABS for the applicable definitions).
*What are the new offering requirements for Caregiver and Housekeeping and Home Maintenance benefits for new business quoting?
Insurers and their intermediaries should assess product suitability and customer needs when presenting options for Caregiver, Housekeeping, and Home Maintenance benefits. For all new business quotes effective on or after July 1, 2026, insurers are required to offer the legislated standard of all impairment for these coverages. Because it provides broader protection, the premium for all impairment will be higher than for catastrophic impairment only. Not all insurers will offer a catastrophic impairment-only buy down; however, those that do may present it when appropriate based on customer need.
If an insurer chooses to default a quote to a single option, that default must be the legislated all impairment option. Insurers may also choose to display both "all impairment" and "catastrophic-impairment-only" options or allow customers to actively select the option that best suits their needs.
*How will existing customers’ Caregiver and Housekeeping and Home Maintenance benefits transition at renewal after July 1, 2026?
On or after July 1, 2026, all existing policies will renew with the same coverage as they had prior to July 1, 2026, until the customer elects to make changes. Customers must be made aware that Caregiver and Housekeeping and Home Maintenance have become optional and that new standards have been established.
They have three possible choices after July 1, 2026:
- keep the same level of coverage
- choose the new standard coverage which applies to all “impairment”
- decline (opt-out) Caregiver, or Housekeeping and Home Maintenance optional coverages entirely
Note that a small number of customers may already have purchased enhanced coverage to include both catastrophic and non-catastrophic impairments.
When will the costing analysis be shared with insurers?
The report was finalized and released to the industry in May.
Are insurers required to use the Oliver Wyman costing analysis and assumptions for pricing?
No. There is no requirement to use the costing analysis and assumptions in the study. Some insurers have limited data and may decide to rely on the analysis and others may feel their own data is sufficient. Insurers should use their best judgment when developing assumptions. If the insurer’s assumption(s) differ from the costing analysis study, an explanation should be provided.
Will there be guidance on minimum premiums for the smaller loss cost coverages?
There is currently no established benchmark for the minimum premium on smaller optional coverages. If an insurer chooses to increase the premium on one of these smaller coverages, it must offset that increase by reducing the premium on other coverages. The key consideration is not the individual pricing of each coverage, but rather the total combined premium across all optional coverages.
If low-cost coverages are rounded up, will the filing still be considered accelerated?
Insurers have the flexibility in setting premiums for the nine optional accident benefit coverages. FSRA will assess whether the total premium across all optional accident benefit coverages is reasonable and aligns with the benchmark. It’s acceptable for low-cost coverages to be priced modestly, even rounded slightly. What’s important is that the overall premium structure remains consistent with expectations and benchmarks.
Our loss distribution for the new optional coverages differs somewhat from those reflected in the benchmark. Are we still eligible to use the benchmark for the accelerated filing path?
If an insurer’s loss patterns differ significantly from those reflected in the benchmark, FSRA recommends that insurers consider the non-accelerated filing path, supported by the necessary actuarial justification. While FSRA strongly encourages the use of benchmark assumptions as a starting point, insurers are expected to adjust their assumptions based on their own post-reform experience where appropriate.
Can an insurer introduce underwriting decline rules for any of the optional accident benefit coverages?
No. Although the coverages are now optional, they are only optional for the insured to purchase. Under the SABS regulation, insurers must offer these accident benefits.
Can an insurer introduce eligibility rules for coverage limits?
An insurer can introduce eligibility rules for new higher coverage limits that allow a consumer to decline a coverage limit pursuant to s. 238 of the Insurance Act, provided that such eligibility rules align with the Insurance Act and FSRA’s fair consumer principles.
How will auto reform filings be organized? Will there be an accelerated path?
Insurers will have two filing paths to choose from:
- accelerated (30 business day decision, file anytime)
- regular (file in the filing window of August to September)
The accelerated path requires use of standard cost benchmarks. The detailed filing specifications including the standard cost benchmarks were shared with the industry by email in May and posted on the FSRA website at the same time. FSRA also hosted an industry webinar in June.
Why is there a filing ‘window’ for auto reform filings if an insurer selects the regular path?
Due to the volume and complexity of filings, FSRA is asking insurers to work with us to file during the ‘filing window’ if they choose not to use the standard benchmarks. However, if an insurer needs an accommodation due to resourcing or other operational constraints, FSRA asks that the insurer give us sufficient advance notice so we can plan accordingly.
Will there be a ‘freeze’ or ‘blackout period’ for rate filings at any time in the next year?
No. There are no restrictions on when an insurer can file and no blackout periods or freezes of any kind.
How did you choose the August-September timeframe for the filing window using the regular path?
We tried to find a timeframe that would make sense for most insurers to implement their changes by July 2026. An earlier timeframe would be too tight for most insurers to make decisions and prepare their filings and created complexities for insurers that file multiple times a year. A later timeframe could put implementation timelines at risk. While there is no perfect window, we proposed the option that worked for most which was August to September.
Do I have to wait until other filings are approved before submitting my auto reform filing?
Ideally, yes. Generally, insurers wait for an approval of one filing before submitting another to avoid potential rework. However, if an insurer has a pending filing that is unrelated to auto reform that will not impact the auto reform filing, they may submit the auto reform filing before waiting for approval of the pending filing.
Can I submit another rate filing after I receive approval for the auto reform filing with an effective date before July 1, 2026?
Yes. However, if the effective date of the subsequent filing(s) is before July 1, 2026, the insurer may need to resubmit the auto reform filing. FSRA would like to avoid this scenario because it leads to rework on both sides.
Can insurers include unrelated changes within the auto reform filing?
Given the volume and complexity of filings, FSRA asks insurers not to include additional changes unrelated to auto reform in the reform filing to ensure an efficient approval process.
What customer communication details are going to be required with the filing? If the toolkit will not be available until the September – November timeframe, what are insurers expected to include in the plan?
Insurers are required to submit a communication plan with their filing; however, actual communication materials are not required. The plan should include a summary of the intended customer communications and training for brokers/ agents (intermediaries).
Will there be a new, special filing type option in ARCTICS since the Single Filing Format covers current components of rate classification, endorsement, forms, and UW rules?
Yes, there will be a new filing type called “Special Filing” in ARCTICS covering rate, endorsements, forms, and rules. The new filing type will use the existing vehicle categories.
Can the OPCF 47R be amended by the insurer? If yes, does the filing of that non- standard form make the entire filing a non-accelerated path?
Yes, insurers can propose to amend the standard OPCF 47R to a non-standard version. Amending the standard OPCF47R to a non-standard form would require filing in the non-accelerated filing path. Please discuss potential changes and rationale with your relationship manager.
Note, if an insurer is using FSRA’s pricing benchmarks to support the rates for a non-standard form in the non-accelerated filing path, the actuarial justification has been considered satisfied.
If the reform filing was submitted prior to the CLEAR 2026 being available, are insurers expected to resubmit the reform filing along with adopting the CLEAR table?
If the CLEAR 2026 table becomes available after an insurer has submitted their reform filing, insurers may follow the current approach to CLEAR impact reporting.
- Option 1 – Insurers implementing CLEAR tables without off-balancing the base rates shall include its rate impact in the next rate filing (including as part of the review of the filing type eligibility).
- Option 2 – Insurers implementing CLEAR tables with off-balancing of the base rates shall submit a rate filing for FSRA's review and approval. This would result in a resubmission of the reform filing if the CLEAR table effective date is prior to July 1, 2026, as the exhibits will no longer be accurate.