PIANY strongly opposes A.10524-A and S.9537, legislation that would significantly reshape how auto insurance is underwritten and priced across New York state.
While the bill is positioned as a consumer fairness measure, its real impact lies in how it would alter the ability of insurers to evaluate risk. That shift has serious implications not only for the insurance market, but for the cost of coverage for New York state drivers.
What the bill would does
A.10524-A would introduce broad restrictions on the underwriting and rating factors insurers can use when issuing and pricing motor vehicle policies.
The legislation would prohibit, or limit the use of, factors such as age, occupation, education, prior insurance history and certain geographic variables. It also would place strict limits on how territorial data can influence premiums, and it would impose new requirements around rate filings, public disclosures and regulatory oversight.
In doing so, the bill would replace a long-standing, data-driven system with a far more restrictive framework that would limit how insurers assess and price risk.
Why underwriting factors are essential
Underwriting is the foundation of how insurance works. At its core, it is the process of evaluating risk and aligning premiums with the likelihood and cost of future claims.
Insurers rely on objective, measurable data to identify patterns that help predict loss. Over time, these factors have been tested, refined and validated through actuarial analysis to improve pricing accuracy.
For example, driving experience can influence accident frequency. Geographic location can reflect differences in traffic conditions, theft rates and repair costs. Prior insurance history can provide insight into coverage patterns and risk behavior.
Using these types of factors allows insurers to group similar risks together and price policies accordingly. This helps ensure that premiums are aligned with expected losses and distributed as fairly as possible across policyholders.
What happens when underwriting is restricted
One of the most important realities in insurance is that risk does not disappear when it is no longer measured. It is simply redistributed.
When insurers are prevented from using established underwriting factors, pricing becomes less precise. As that precision declines, insurers must broaden their pricing assumptions to account for uncertainty.
The result is a shift in costs across the market. Often, lower risk drivers end up paying more, while overall premiums rise to compensate for the reduced ability to accurately match price with risk.
If enacted, this legislation would increase costs for consumers across New York state drastically. By limiting the tools insurers rely on to evaluate risk, the bill would force a less accurate pricing system that ultimately drives premiums upward for a large portion of the market.
Impact on market stability and competition
Insurance markets depend on stability, predictability and the ability to price risk appropriately.
A regulatory environment that restricts underwriting tools and adds significant compliance burdens can make it more difficult for insurers to operate effectively. Over time, this can lead to reduced market participation, fewer product options and less competition.
Typically, when competition declines, consumers face higher premiums and fewer choices.
The role of geographic rating
Geographic data remains one of the most reliable indicators of insurance risk. Accident frequency, theft rates, medical costs and repair expenses can vary significantly by location.
The bill would limit how insurers can use territorial factors and caps their impact on premiums. While intended to address fairness concerns, these restrictions would reduce pricing accuracy, and they would create unintended cost shifts between regions.
Drivers in lower risk areas may end up subsidizing higher risk areas, further contributing to rising premiums.
A question of balance
Fairness and transparency are important goals in any insurance system. The challenge is achieving those goals without undermining the principles that allow insurance markets to function effectively.
A.10524-A takes a broad and restrictive approach that moves away from time-tested underwriting practices. In doing so, it introduces uncertainty into pricing, places pressure on market stability and increases the likelihood of higher costs for consumers.
Final thoughts
Underwriting is not about limiting access to coverage. It is about using data to align price with risk in a way that keeps the system sustainable for everyone.
When insurers have the tools to evaluate risk accurately, the market functions more efficiently and premiums more closely reflect individual exposure. When those tools are restricted, the result often is higher costs, reduced competition, and fewer options for consumers.
For these reasons, PIANY strongly opposes A.10524-A and S.9537, and the association urges policymakers to consider the broader impact this legislation would have on affordability and market stability in New York state.
Joseph Ritchie
Joe Ritchie joined PIA Northeast as government and industry affairs coordinator for the Government & Industry Affairs Department in 2025, where he supports the association’s legislative, regulatory and member-advocacy initiatives across the Northeast. Prior to joining PIA, Joe served as the Advocacy & Policy Coordinator at Riverkeeper, working closely with municipal leaders, environmental organizations, and state agencies to advance clean water protections in the Hudson Valley. Previously, he worked as the Administrator of Government Affairs at Spectrum, where he managed statewide regulatory filings, supported broadband deployment efforts, and coordinated communications with policymakers. Joe also spent time in the New York State Assembly, assisting Assemblymember Kevin Cahill during his tenure as Chair of the Insurance Committee, where he contributed to committee meeting preparations, legislative research and constituent support. In addition to his government affairs work, Joe is the co-founder and Chair of Lights Out Norlite, a community-based environmental justice initiative focused on improving public health and industrial oversight in the Capital Region. He received his bachelor’s degree from Syracuse University and remains an active supporter of Syracuse Football. Outside of work, Joe enjoys cooking Italian meals for his wife, spending time with his family and camping throughout the Adirondacks.
