How to Fill Out NAIC Form MCAS (w/Examples) + FAQs

The NAIC Market Conduct Annual Statement (MCAS) is a mandatory, state-by-state data filing that licensed insurers submit through the NAIC’s online MCAS application to report claims, underwriting, and complaint data for each line of business they write. State insurance regulators use this data to spot companies that treat policyholders unfairly, so a sloppy or late filing can put your company on a regulator’s radar fast.

If you have never filed an MCAS before, the task can feel overwhelming. You are pulling raw data from claims systems, matching it to strict definitions, and submitting separate filings for every state and every line you write. As of the 2024 data year, 51 jurisdictions participate in MCAS, and that number keeps growing, which means more filings and less room for error each year.

In this guide, you will learn:

• 📋 What the MCAS is, who must file it, and the exact premium thresholds that trigger a filing
• 🗂️ Every document and number you need to gather before you open the submission tool
• ✍️ A line-by-line walkthrough of the core MCAS data elements, with named examples
• 🧾 Three full filing scenarios for Private Passenger Auto, Individual Life, and Health
• ⚠️ The mistakes that get companies flagged and how to avoid them

What the Form Is and Who Must File It

The MCAS is a uniform data call that the National Association of Insurance Commissioners built in 2002 so states could collect market conduct data in one consistent format. Instead of each state sending its own survey, insurers report claims, underwriting, complaint, and lawsuit data through a single NAIC platform. Each participating state then pulls its own data and builds scorecards that compare your company against the rest of the market.

You must file if your company is licensed in a participating state and writes premium at or above that line’s threshold in that state. The 2025 Participation Requirements document lists 13 reporting lines, including Private Passenger Auto, Homeowners, Individual Life, Individual Annuity, Health, Disability Income, Long-Term Care, Lender-Placed Auto and Home, Private Flood, Travel, Pet, and Short-Term Limited Duration Insurance. Most lines use a $50,000 direct premium written threshold, while Long-Term Care, Travel, and Pet have a $0 threshold, meaning even one dollar of premium triggers a filing.

A key rule trips up new filers: each company in a holding company system files separately. You cannot combine data for a group into one filing. If your group owns three insurers that each write auto in Texas, you file three separate Texas auto MCAS filings, one per company code.

For the 2025 data year, New York participates for the first time, so companies writing covered lines there must now report New York data too. New York receives a one-time, one-month extension for its 2025 submissions.

Before You Start: Documents and Information You Need

The MCAS pulls from your claims system, your policy administration system, and your complaint logs. Gathering everything first saves hours of back-and-forth. Missing even one item can stall a filing or force you to amend it later.

• NAIC Company Code. This is your unique five-digit identifier. Without it, the system cannot tie your filing to the right legal entity, and a wrong code files data under another company.
• MCAS login credentials. You need an active account in the NAIC’s MCAS application; without one you cannot open or submit any blank.
• The call letter. The NAIC mails this in mid-December and it tells you which states and lines expect data from you. Ignoring it does not remove your duty to file.
• Direct premium written by state and line. You need this to confirm you cross each threshold; underreporting can wrongly exempt you and trigger a non-filing penalty.
• Policy counts in force and new business counts. These feed the underwriting section, and bad counts skew your ratios.
• Claims data by status. You need claims opened, closed with payment, closed without payment, and the days each took, because the claims section is the heart of MCAS.
• Complaint records. Count complaints received directly and through the department of insurance, since regulators match these against their own logs.
• Lawsuit counts. Track suits opened and closed during the year, as the lawsuit interrogatories are a common audit point.
• Replacement counts (Life and Annuity). You report internal and external replacements, and a missing count here can suggest churning.
• The correct year’s blank and definitions. Download the matching Data Call and Definitions so your numbers match the current rules.

Where to Get the Form and How to Access It

There is no paper MCAS form. You report everything through the NAIC’s online MCAS application, which opens for 2025 data filings on March 13, 2026. You reach it through the Log In button on the MCAS web page, and if you lack an account you click the “Don’t have an MCAS login?” link to request one.

Before you key in numbers, download the two core resources for each line: the Data Collection Worksheet (Blank), which shows the table layout of every data element, and the Data Call and Definitions (Instructions), which defines each element. For 2025, the Private Passenger Auto blank is version 2025.0.2 and the Life and Annuity definitions are version 2025.0.0, so always confirm you have the current revision printed on the document.

You can enter data two ways inside the tool. You can key it directly into the online blank, or you can upload a CSV file built from the NAIC’s CSV Assistant Files. Large filers usually use CSV upload to file dozens of state-and-line combinations at once, while small filers often key data by hand.

Keep the 2025 MCAS User Guide open while you work. It lists the validation errors and warnings the system throws, which helps you fix problems before you submit rather than after.

Step-by-Step: How to Fill Out the MCAS Line by Line

The MCAS is organized into sections that repeat across lines of business: company identification, the interrogatories, the underwriting (policy) data, the claims data, the complaint and lawsuit data, and the attestation. Below, each major data element gets its own walkthrough. Use the exact field labels from your line’s Data Call and Definitions, because the platform validates against those labels.

1. Company Identification (NAIC Company Code and Company Name)

This field asks which legal entity is filing and ties every number to one company. You answer by confirming the five-digit NAIC Company Code and legal name the system pre-fills from your login. Acme Mutual Insurance Company confirms its code reads 12345 and its name matches its certificate of authority.

If your company recently changed its name after a merger, report under the corporate structure in effect on the last day of the reporting period. The most common mistake here is filing under a parent’s code instead of the writing entity’s code, which buries your data under the wrong company and can show another insurer as a non-filer. A common misconception is that one filing covers the whole group; in truth, each entity files on its own.

2. Reporting State and Line of Business

This field asks which state and which product line this specific filing covers. You answer by selecting the state and line from the dropdown, then completing one full blank for that pair. Acme writes auto and home in both Texas and Ohio, so it opens four separate blanks: Texas Auto, Texas Home, Ohio Auto, and Ohio Home.

If you write a line in a state but fall below the threshold, you may not need to file, but you should still confirm your premium total. The common mistake is combining two states’ data into one blank, which corrupts both states’ scorecards. People often believe national totals are acceptable, but MCAS is strictly state-specific.

3. Interrogatories (Yes/No Threshold and Activity Questions)

The interrogatories ask plain yes/no questions, such as whether you wrote the line in that state and whether you used a managing general agent. You answer each with a clear Yes or No, and your answers control which later sections you must complete. Brightside Life answers Yes to writing individual life in Florida, which opens the full Florida life blank.

If you answer No to writing the line, the system may close the rest of the blank, so answer carefully. The common mistake is answering No to avoid work when you did write business, which is a misrepresentation that regulators can act on. A frequent misconception is that interrogatories are optional background; they are mandatory and drive the whole filing.

4. Policies In Force at Year End

This field asks how many policies were active on December 31 of the data year. You answer with a whole number, counting each in-force policy once, with no dollar signs or decimals. Acme enters 18,420 in-force auto policies in Texas.

If a policy lapsed and reinstated during the year, count it as in force only if it was active on December 31. The common mistake is reporting written policies instead of in-force policies, which inflates the denominator and distorts every ratio built on it. People wrongly assume canceled mid-year policies still count; they do not if they were inactive at year end.

5. New Business Policies Written or Issued

This field asks how many new policies you issued during the data year. You answer with a whole-number count of new issues, excluding renewals. Brightside Life issued 2,310 new individual life policies in Florida, so it enters 2,310.

If a policy was issued and then canceled in the free-look period, follow your line’s definition on whether it counts as issued. The common mistake is including renewals in the new-business count, which overstates growth and skews replacement ratios. A misconception is that quoted-but-not-bound applications count; only issued policies belong here.

6. Claims Opened During the Period

This field asks how many claims you received during the data year. You answer with a count of claims first reported in the year, regardless of when they close. Acme enters 1,205 auto claims opened in Texas.

If a single event generates multiple coverage claims, follow the definition on whether to count claims or claimants. The common mistake is counting claim payments instead of claims, which double-counts multi-payment claims. People often think reopened claims start a new count; usually they do not, so check the definitions.

7. Claims Closed With Payment

This field asks how many claims you closed and paid during the year. You answer with a whole-number count of paid, closed claims. Acme enters 1,040 Texas auto claims closed with payment.

If a claim was partially paid and remains open, do not count it as closed. The common mistake is mixing closed-with-payment and closed-without-payment, which throws off the claims-settlement ratios regulators watch closely. A misconception is that any payment closes a claim; a claim is closed only when your system marks it final.

8. Claims Closed Without Payment

This field asks how many claims you closed without paying anything. You answer with a count of denied or zero-pay closed claims. Acme enters 165 Texas auto claims closed without payment.

If you closed a claim because the loss fell below the deductible, it still counts here as closed without payment. The common mistake is treating all no-pay closes as denials, when some are withdrawals; the definitions separate these. People assume a high no-pay count always looks bad, but context like deductibles matters to analysts.

9. Claims Closed Within Aging Buckets (0-30, 31-60, 61-90, 91-180, 181-365, Over 365 Days)

This field asks how fast you closed claims, sorted into day-range buckets. You answer by counting closed claims in each bucket so the buckets sum to your total closed claims. Acme enters 620 claims closed in 0-30 days and smaller counts in each later bucket.

If a claim reopened and reclosed, measure the aging per your line’s definition, usually from the original report date. The common mistake is buckets that do not add up to total closed claims, which is a hard validation error that blocks submission. A misconception is that calendar days exclude weekends; MCAS counts all calendar days.

10. Complaints Received

This field asks how many complaints you received, often split between those sent directly to you and those routed through a department of insurance. You answer with whole-number counts in each category. Brightside Life enters 14 DOI complaints and 9 direct complaints in Florida.

If one complaint touches two policies, count it once unless the definition says otherwise. The common mistake is reporting only DOI complaints and omitting direct ones, which understates your complaint ratio. Regulators match DOI complaints against their own logs, so a misconception that they cannot verify your number is false.

11. Lawsuits Opened and Closed

This field asks how many lawsuits you had open at the start, opened during, and closed during the year. You answer each with a whole-number count, following the line’s definition of a lawsuit. Acme enters 7 auto lawsuits opened during the year in Texas.

If a lawsuit covers several claims, count the suit once. The common mistake is counting arbitrations or appraisals as lawsuits, which inflates the count; only true lawsuits belong. People wrongly believe small-claims actions never count, but many definitions include them.

12. Replacements (Life and Annuity Lines)

This field asks how many policies were replacements, split into internal and external. You answer with whole-number counts for each type. Brightside Life enters 120 internal and 95 external replacements in Florida.

If a replacement was initiated but not completed, do not count it. The common mistake is reporting all new business as non-replacement when some were replacements, which can hide churning patterns. A misconception is that internal replacements do not matter; regulators track them closely for suitability concerns.

13. The Attestation and Submission

This field asks an authorized officer to attest the data is true and complete. You answer by having the designated signatory review the blank, clear all validation errors, and submit through the tool. Brightside Life’s compliance officer reviews the Florida blank, fixes one warning, and clicks submit.

If you submit with unresolved hard errors, the system blocks you, so resolve them first. The common mistake is submitting before reconciling claim counts, which forces a later amendment that flags the company. A misconception is that you can edit freely after submission; corrections after the deadline follow a strict process.

Three Filled-Out Examples Using Real Scenarios

Below are three named filers walking through the core sections of their MCAS blanks. Each shows what the company enters in the most important fields.

Scenario 1: Acme Mutual files Private Passenger Auto in Texas

Form Section	What Acme Enters
NAIC Company Code	12345
Reporting State and Line	Texas / Private Passenger Auto
Wrote line in state? (Interrogatory)	Yes
Policies In Force at Year End	18,420
New Business Policies Written	3,150
Claims Opened During Period	1,205
Claims Closed With Payment	1,040
Claims Closed Without Payment	165
DOI Complaints Received	11
Lawsuits Opened During Period	7

Scenario 2: Brightside Life files Individual Life in Florida

Form Section	What Brightside Enters
NAIC Company Code	67890
Reporting State and Line	Florida / Individual Life
Wrote line in state? (Interrogatory)	Yes
Policies In Force at Year End	45,600
New Business Policies Issued	2,310
Internal Replacements	120
External Replacements	95
Claims Closed With Payment	310
Direct Complaints Received	9
DOI Complaints Received	14

Scenario 3: Coral Health files Health in California

Form Section	What Coral Health Enters
NAIC Company Code	54321
Reporting State and Line	California / Health
Earned premium meets threshold?	Yes
Member Months / Policies In Force	512,300
Claims Opened During Period	88,400
Claims Closed Within 0-30 Days	61,200
Claims Closed Without Payment	7,150
DOI Complaints Received	altogether 42
Lawsuits Opened During Period	5
Attestation Signed By	Compliance Officer

Note that Coral Health files on a later schedule, since Health is due May 31, 2026 rather than April 30.

How to File the Completed Form

The MCAS uses one channel: the NAIC’s online MCAS application. There is no mail, fax, or in-person option, because the data flows directly into the NAIC platform that states query. You log in, open each state-and-line blank, enter or upload your data, clear validations, and submit.

You file using one of two methods inside the tool. Manual data entry works for a few filings, where you key numbers straight into each blank. CSV upload works for many filings, where you build files from the CSV Assistant Files and upload them in bulk.

The NAIC charges no fee to file the MCAS itself, but some states add their own fee through their own systems. For example, Oklahoma charges a $200 filing fee per filing, paid electronically through OPTins, since paper checks are no longer accepted there. Always check your state’s bulletin for fees and payment methods.

Mind the deadlines, which the 2025 MCAS key dates set clearly. Most lines are due April 30, 2026, while Health, Other Health, and STLD are due May 31, 2026. After you submit, save the confirmation the system generates and keep a copy of each blank, because that confirmation is your proof of timely filing.

What Happens After You File

Once you submit, each participating state pulls its own data from the NAIC platform and runs it through standardized ratio formulas. The NAIC posts industry scorecards on the MCAS web page by July 1, 2026, for most lines and by August 1, 2026, for Health, Other Health, and STLD. These scorecards show the statewide ratio and how every filer’s ratios are distributed.

State market analysts compare your ratios against the rest of the market. If your claims-denial rate, complaint ratio, or settlement timing stands out, an analyst may open a deeper review. The MCAS itself is not an exam, but it often decides who gets examined.

You can view aggregated results on the MCAS Data Dashboard, which posts data roughly 60 days after the deadline. If you discover an error after filing, you must follow the correction process, since the last day to submit prior-year corrections is in late January of the following year. Late or missing filings can lead to state fines, administrative action, or scrutiny of your certificate of authority.

Mistakes to Avoid When Filling Out the Form

Each MCAS field is its own chance to err, so review this list before you submit.

• Filing under the parent company’s NAIC code, which buries your data under the wrong entity.
• Combining multiple states into one blank, which corrupts every affected state’s scorecard.
• Combining group members into one filing, which violates the separate-filing rule and can show entities as non-filers.
• Reporting written policies instead of in-force policies, which distorts every downstream ratio.
• Letting claim aging buckets fail to sum to total closed claims, which blocks submission.
• Mixing closed-with-payment and closed-without-payment counts, which skews settlement ratios.
• Omitting direct complaints and reporting only DOI complaints, which understates your complaint picture.
• Counting arbitrations or appraisals as lawsuits, which inflates the lawsuit count.
• Using last year’s blank or definitions, which causes data to map to the wrong elements.
• Missing the threshold check and filing nothing when you actually crossed $50,000, which triggers a non-filing penalty.
• Submitting before reconciling data, which forces a flagged amendment after the deadline.
• Ignoring the call letter, which does not remove your duty and leaves you exposed to fines.

Do’s and Don’ts

Do:

• Download the current-year blank and definitions first, so your numbers map correctly.
• Confirm your NAIC Company Code before entering any data, because it anchors the whole filing.
• Reconcile claim counts so closed-with and closed-without payment add up cleanly.
• File a waiver request early through the tool if you qualify, since waivers are not automatic each year.
• Save your submission confirmation, because it proves you filed on time.
• Calendar the April 30 and May 31 deadlines separately, since lines have different due dates.

Don’t:

• Combine states or group members, because MCAS demands separate filings.
• Answer interrogatories falsely to skip work, since that is a reportable misrepresentation.
• Assume last year’s waiver carries over, because you must re-request it.
• Wait until the deadline to fix data, since corrections after the cutoff follow a strict process.
• Treat DOI complaint counts as unverifiable, because regulators match them to their own logs.
• Ignore validation warnings, since they often flag real data problems.

Pros and Cons of Filing on Your Own vs. With Help

Some companies file MCAS in-house, while others hire consultants or use filing software. Here is how the two approaches compare.

Pros of filing on your own:

• You save consultant fees, which matters for small insurers with few filings.
• You keep full control over your own data and definitions.
• You build internal expertise that helps in future years.
• Direct entry is fast when you file only a handful of state-and-line blanks.
• You avoid sharing sensitive claims data with outside parties.

Cons of filing on your own:

• You carry the full risk of misreading definitions, which can skew ratios.
• Bulk filing across many states gets time-consuming without CSV tooling.
• You may miss subtle validation rules that a specialist would catch.
• Staff turnover can erase your filing knowledge year to year.
• Errors that trigger a market conduct exam can cost far more than consultant fees.

FAQs

Is the MCAS a paper form I can mail in?

No. The MCAS is filed only through the NAIC’s online MCAS application. There is no mail, fax, or in-person option, since data flows directly into the NAIC platform that states query.

Do I have to file separately for each state?

Yes. MCAS is state-specific, so you complete one blank for each state-and-line combination you write, and you cannot combine states into a single filing.

Can my insurance group file one combined MCAS?

No. Each company in a holding company system files separately. Group data cannot be combined into one filing for any state or line.

Is there a premium threshold that triggers a filing?

Yes. Most lines use a $50,000 direct premium written threshold, while Long-Term Care, Travel, and Pet have a $0 threshold, meaning any premium triggers a filing.

Do I report policies written or policies in force in the in-force field?

No. In the “Policies In Force at Year End” field you report only policies active on December 31, not all policies written during the year.

Should I count renewals as new business?

No. The “New Business Policies Written” field counts only newly issued policies. Including renewals overstates new business and skews replacement ratios.

Do claim aging buckets need to add up to total closed claims?

Yes. The aging buckets must sum to your total closed claims, or the system throws a hard validation error that blocks your submission.

Do I report complaints sent only to the department of insurance?

No. You report both DOI complaints and complaints sent directly to your company, since omitting direct complaints understates your complaint ratio.

Does an arbitration count as a lawsuit in the lawsuit field?

No. Only true lawsuits count under most definitions. Counting arbitrations or appraisals inflates your lawsuit numbers and misstates your data.

Is there a fee to file the MCAS?

No. The NAIC charges no fee, though some states add their own, such as Oklahoma’s $200 fee paid through OPTins.

Is the Health line due on the same date as Auto?

No. Most lines are due April 30, but Health, Other Health, and STLD are due May 31 for the 2025 data year.

Does last year’s waiver carry over to this year?

No. Companies waived in prior years are not automatically waived again. You must submit a new waiver request through the tool each year.

Do I file New York data for the 2025 year?

Yes. New York participates for the first time for 2025 data, with a one-time, one-month extension for its submissions only.

Can I edit my filing freely after I submit it?

No. After submission, corrections follow a strict process, and the last day to submit prior-year corrections falls in late January of the following year.