How to report declinations and nonrenewals under Texas HB 2067

If your company writes property-casualty insurance in Texas, a quietly significant reporting duty is already in force. House Bill 2067 (89th Legislature, 2025), effective January 1, 2026, added Insurance Code Section 551.006: an insurer must give the Texas Department of Insurance (TDI), at least once each quarter, a written report summarizing its reasons for declining applications and for canceling or not renewing policies, organized by the applicant's or policyholder's ZIP code. The report is a quarterly summary, so the task in front of operations teams is less legal than clerical: your underwriters already record these reasons, but they record them as prose, and the report wants them as structured, categorized, ZIP-coded counts.

This article explains what the law asks for, where Texas is in rolling it out, and a practical way to turn the reasons your team already writes into the quarterly report — without re-keying decline letters at the end of every quarter. It is an operating method, not legal advice, and the exact commercial-lines format is still being finalized, so treat the field layout as provisional.

It is written for the regulatory-reporting, compliance, or operations lead at a Texas carrier, and for the managing general agents (MGAs) and program administrators who make these coverage decisions and write the consumer notices on a carrier's behalf. The statutory filing duty sits with the insurer, but the reason data usually originates wherever the decision is made. In Dallas-Fort Worth and Houston, two of the state's largest insurance markets, that work is often split across a carrier and one or more delegated programs, which is exactly where the data tends to fragment.

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What HB 2067 actually requires

The headline change is a quarterly summary report to TDI, not a new consumer notice. Texas law already requires an insurer to tell an applicant or policyholder the reason for a declination, cancellation, or nonrenewal. HB 2067 adds a second obligation on top of that: the insurer must now report a summary of those same reasons to TDI at least quarterly, organized by the applicant's or policyholder's ZIP code (workers' compensation is reported statewide). TDI then posts an aggregated public summary of the reports that may not identify any individual insurer, per the enrolled bill.

Two practical points follow. First, this is a count-and-categorize exercise: TDI wants the distribution of your decision reasons by geography, not a copy of each decline letter. Second, the reason codes TDI publishes are for the statistical report only. Your consumer notices still need a full, specific description of why a particular applicant was declined; the proposed commercial-lines instructions say insurers should not substitute TDI's reason codes for that explanation.

Where Texas is in the rollout

The statutory duty applies now, but TDI is phasing in the actual reporting mechanics by line of business, according to its July 2025 bulletin (B-0008-25). Personal lines went first: TDI updated the residential property and private passenger auto statistical plans, which took effect February 4, 2026, for use starting April 1, 2026. Commercial lines are next. TDI proposed amendments to the Texas Commercial Lines Statistical Plan (28 TAC Section 5.9501) in the Texas Register, held a hearing on June 15, 2026, and closed public comment on June 22, 2026. Under that proposal, farm and ranch and farm and ranchowners lines would report monthly and all other covered commercial lines quarterly, with the revised plan proposed to apply to reporting periods beginning October 1, 2026.

As of October 24, 2026 we could not confirm a final adoption order for the commercial-lines amendment, so treat its fields and dates as proposed and verify the current status with TDI. The point for planning is the same either way: the law is in effect, and the format for commercial lines is converging, so the useful move is to start capturing clean reason data now rather than reconstructing a quarter of decisions after a rule is finalized.

Why this is a data problem, not a filing problem

The report is only as good as what gets recorded at the moment of the decision. In most shops, a declination reason lives in three or four places at once: a checkbox or free-text field in the underwriting or policy-administration system, the body of the adverse-action letter, an email thread with the agent, and sometimes only in an underwriter's notes. None of those is a clean, categorized, ZIP-tagged record. At quarter end, someone is then asked to read back through a quarter of decisions and bucket them — which is slow, inconsistent between people, and hard to audit.

The design question is therefore where to capture the reason as structured data, and who owns the cases that do not fit a code. Get that right and the quarterly report becomes a query, not a project.

A workflow for turning reasons into the quarterly report

The three-step method below is our own operating recommendation, not a TDI-approved procedure or legal advice. It has three steps, and it assumes you already generate the consumer notices the law requires.

1. Capture the reason as a code at the point of decision. When an underwriter declines, cancels, or nonrenews, require a structured reason selected from a short internal list, alongside the free-text explanation that goes to the consumer. Store it on the transaction with the ZIP code of the applicant or policyholder and the line of business. The free text still drives the letter; the code drives the report.

2. Map your internal codes to the reporting categories. Keep your own reason list stable and maintain a translation table to TDI's categories, so a change in the reporting layout is a mapping edit rather than a retraining exercise. A first mapping usually looks like this:

The internal codes are yours to define; the right-hand column must be reconciled against the current adopted TDI layout before you file, because that layout is still being finalized for commercial lines.

3. Reconcile and assign an owner before you file. Two counts should match: the number of adverse-action notices sent in the quarter and the number of coded reason records. A gap means a decision went out without a captured code, and that is the exception a person owns. Decide in advance who resolves an uncoded or "other" decision, who signs the filing, and what happens when a delegated program reports late. Insured-initiated cancellations and first-term cancellations are easy to miscount, so separate them explicitly rather than letting them fall into a catch-all.

Worked example (illustrative). The figures in this example are illustrative and do not describe any real insurer. Suppose a program writes 2,000 commercial decisions in a quarter and sends 2,000 notices, but only 1,840 carry a structured code. The 160-record gap is the quarter's real work: pull those decisions, have an underwriter assign a code or confirm "other," and record why. If 60 of the 160 turn out to be insured-requested cancellations miscounted as nonrenewals, that single correction changes the shape of what you report. The lesson is that the reconciliation step, not the data pull, is where accuracy is won or lost.

This method does not tell you how a specific risk should have been classified, and it cannot promise your filing is complete — a person still owns the ambiguous cases and the sign-off. What it does is make the quarterly report reproducible: the same decisions, coded the same way, by whoever runs it.

What to do before the next filing

You do not need the final commercial-lines rule to start. Confirm that every adverse-action decision writes a structured reason code and a ZIP code today; build the mapping table and keep it versioned; and name the owner for exceptions and sign-off. A carrier working with MGAs should agree on a single code list and a submission deadline so delegated decisions arrive in the same shape. When TDI's commercial format is final, you are editing one mapping table instead of rebuilding the process under a deadline.