Filing Guidelines - Frequently Asked Questions
(updated June 1, 2016)

Under the Automobile Insurance Premiums Regulation (effective July 1, 2014).

Updates to the FAQs

FAQs - Category Index


Initial Filing of Current Rating Programs

  1. Section 3 of the Premiums Regulation states that all rating programs (all categories of vehicles and garage risks) currently in use are deemed approved and insurers must file with the Board their rating programs. However, the policies state that insurers need to submit a full filing after the Premiums Regulation takes effect. Why the discrepancy?

    AIRB Bulletin 01-2014 and Bulletin 02-2014 require insurers to file a digital version (pdf) of their rating programs with the Board by the dates outlined in each Bulletin. This will ensure that the AIRB has on file a current copy of all company rating programs. No filing will be reviewed until the insurer submits its initial filing with the AIRB.

    Please note the initial submission of current rating programs is different from the first full filing.

    The first full filing requirement described in the policies refers to an insurer’s first proposal to revise its rating program through an increase in rate level or revision to differentials for any rating variables that can result in an increase in premium level for any policyholder. There is no set schedule for full filings. However, a full filing is required where an insurer wants to revise its rating program and one has not been filed and approved within the past three years.

  2. Does an insurer have to submit a full filing for the initial filing for revisions to its rating program?

    An insurer must submit a full filing for any proposed change, with the following exceptions for which a simplified filing approach can be used:
    • where the insurer proposes to revise an endorsement, or
    • where the insurer proposes to introduce a discount related to a single variable, or
    • where the insurer proposes a decrease or revenue neutral adjustment in premium level for basic coverage and for additional coverage, with no increase of greater than +10% in a differential for any rating variable.

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Filing Timelines

  1. How far in advance of its target implementation dates should an insurer submit a filing?

    The AIRB's target to issue a decision on a full filing is 60 days from when the filing materials are deemed complete. The target for a simplified filing is 30 days once deemed complete. In either situation, insurers are encouraged to contact AIRB staff to determine if their filing meets the eligibility requirements for simplified filing, and the estimated amount of time the Board will require to review the filing and issue its decision. Where a filing is more complex, e.g. unbundles a rating program, expect targets to be extended.

  2. What are the parameters around the annual +3% to premium level available under a simplified private passenger filing?

    The annual period for the administrative threshold of +3% in premium level for private passenger commences with the implementation date of the full filing. An insurer has an opportunity to take the equivalent of 2 increases of up to +3% each between private passenger full filings. An insurer could implement 3 separate increases of approximately 2%, not exceeding +6% in total. The +6% must be accrued over two annual periods; an insurer cannot apply for the full 6% in the first year following a full filing. The following bullets may provide further clarity:

    • An insurer obtains approval for a full filing that is implemented on November 1, 2014. The insurer can then make limited adjustments to its rating program through simplified filings during the 3-year period ending October 31, 2017. The assumption is that the revision effective November 1, 2014 forecast premium requirements through to October 31, 2015. The insurer can file for all or part of the +3% adjustment for the following policy year (November 1, 2015 to October 31, 2016) or carry it over to the policy year commencing November 1, 2016.

    • If the insurer’s full filing approved for November 1, 2014 did not achieve rate adequacy, the Board could allow a further increase through a simplified filing for implementation during the policy year, November 1, 2014 to October 31, 2015.

    • If for some reason, the insurer implements +3% in the first year (November 1, 2014 to October 31, 2015) and +3% in the second year, then no further increase would be available in the third year (November 1, 2016 to October 31, 2017) through a simplified filing.

    • Updated February 1, 2016:
      If the insurer’s full filing approved for November 1, 2014 achieved rate adequacy, insurers must wait for 6 months to be able to take up to 3% following the effective date of a full filing. If the immediate rate need can be supported, the Board may accept the simplified filing and waive the 6 month period.

    • The increase in premium level through simplified filings cannot exceed +6% over the three year period ending October 31, 2017.

    • If the insurer submits and receives approval for another full filing before the 3-year period expires, for implementation on April 1, 2016, the time period for increases under a simplified filing would reset for three years from April 1, 2016.
  3. Question added February 1, 2016:
    Will adjustments to trend rates, health levy, premium tax, etc. impact the 3% simplified filing threshold?


    No. These adjustments can be reflected in a simplified filing, but still be capped at 3% as the maximum increase an insurer can take through a simplified filing.

  4. Question added February 3, 2016:
    Does the 20% dislocation cap apply to CLEAR filing? What happens if insurers are submitting a combined filing with CLEAR update?

    The 20% dislocation cap does NOT apply to CLEAR filing. In the case that a combined filing is submitted, insurers are required to provide a dislocation table for the changes other than CLEAR update to make sure the dislocation criteria is met. The AIRB is making continued efforts to balance between the need for rate adequacy from insurers and manageable premium impact to policyholders. The AIRB encourages insurers to do their best to manage dislocation.

  5. What timelines and communication can an insurer expect from the Board on the status of its filing?

    The AIRB will acknowledge receipt of the filing within 2 business days. The AIRB will review the filing and notify the insurer if the filing material is complete within 10 business days. The AIRB will request the insurer to provide additional information if the filing material is not complete. The responses may prompt further questions. The filing will be deemed complete once the AIRB has the required information.  The insurer should then expect the Board to complete its review and render a decision within 30 days for a simplified filing and 60 days for a full filing. The AIRB staff will contact the insurer regarding its recommendation prior to the filing being presented to the Board. The insurer may contact AIRB staff to discuss the issues and provide further information if the insurer does not agree with the staff's recommendation. Alternatively, the insurer may request to attend the Board meeting to present their concerns.

    The insurer is encouraged to contact AIRB staff regarding its filing status at any stage.

  6. When is an insurer requested to submit the mandatory full filing?

    AIRB requires an insurer to submit a full filing on a 3-year cycle, which starts from the effective date of the latest full filing. If the insurer needs to postpone the effective date after the filing is approved, it can do so by notifying AIRB of the revised date and the reason for the delay, e.g., IT issues. The 3-year cycle starts on the revised renewal effective date. Once the 3 -year cycle has elapsed, any change to the rating program after that date requires a full filing. E.g.

    • An insurer obtains approval for a full filing that is implemented on November 1, 2014. The insurer can then make limited adjustments to its rating program through simplified filings during the three-year period ending October 31, 2017.

    • The insurer next submits a filing on July 1, 2018 to increase the premium level by 3% effective on December 1, 2018. This proposal would require full filing.

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Full Filing vs. Simplified Filing

  1. An insurer is planning to make changes to its current rating program, but is not sure if a full or simplified filing is required.

    The filing guidelines provide a complete listing of criteria for full and simplified filings; separate PPV and Other than PPV sections. Insurers are encouraged to contact AIRB staff to discuss their situation to establish the correct procedure.

  2. How is the +3% threshold for adjusting premium level under a simplified filing derived? Will it be adjusted in the future?

    The +3% threshold for premium increases for private passenger rating programs is an administrative threshold for the AIRB to expedite fine-tuning of rating programs through simplified filings to facilitate quick response to market.

  3. An insurer filed a voluntary rate reduction last year, and the market experience is showing adverse development. What can it do to recoup the rate reduction?

    If there is no full filing after the voluntary rate reduction and it is not the third year when a full filing is required, the insurer is eligible to recoup all or part of the voluntary rate reduction through a simplified filing. It is also eligible for the +3% in premium level available under a private passenger simplified filing. The insurer must submit a full filing if three years have elapsed since its last full filing.

    If the insurer wants to simply reverse all or part of the previous changes, it can do so with no restrictions. However, if the insurer wants to go back to the previous rate level by proposing other changes, the proposal must come within the parameters permitted by a simplified filing. The overall increase allowed is the reversal of the previous rate reduction plus any remaining balance of the +3% adjustment permitted under a simplified filing.

  4. What should an insurer do if it is proposing to introduce a new rating variable?

    If the rating variable is new to the Alberta market, the insurer must request approval from the Superintendent's Office prior to including it in a filing to the AIRB.  An insurer would apply directly to the AIRB if it wants to add a variable that has been approved for use in Alberta. A full filing is required to add rating variables to a rating program.

  5. If an insurer has not taken all the IWA increases available under Orders 01-12 and 01-13 by July 1, 2014, can it still take the increase without submitting a full filing?

    Yes, the insurer can still take the IWA increase without submitting a full filing. The IWA adjustment can be carried over for up to 3 years or until its first full filing has been approved.

  6. In “AIRB Guidelines for Other Than Private Passenger Full Filing”, one of the scenarios in which a full filing is required is “the insurer has not filed for this category within the last 3 years and a rate change of 10% or more is proposed". Does this mean that if an insurer has not filed for this category in the last 3 years and is proposing a rate change for less than 10%, that a simplified filing may be used?

    Yes. An insurer can file using a simplified filing as long as no other scenario in the guideline applies to it. However, the Board can request a full filing at any time as it sees fit.

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Filing Format

  1. Are filing materials required in both PDF and Excel format?

    All filing materials must be in PDF format; the actuarial support must also be provided in Excel format. The Excel spreadsheets should include all formulas with clearly indicated references.

  2. How does an insurer submit a filing?

    An insurer should submit filing materials electronically to AIRB@gov.ab.ca. If the file size is too large to send, the insurer should establish a secured file transfer path with AIRB staff. If the insurer does not have access to this tool, the insurer can contact AIRB staff to request a one-time use path.

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Filing Review

  1. How will the ratemaking components be reviewed? Will the filing be rejected simply because an insurer’s expense and profit provisions or loss trends are not in line with the Board’s guidelines?

    The Board will consider its consulting actuary’s report, which includes recommended loss trend rates for PPV and commercial vehicles to establish guidelines. The guidelines for PPV loss trend rates will be updated semi-annually, and will be developed annually for commercial vehicles. The consulting actuary’s report will consider stakeholder's comments. Once the guidelines have been established, they will be used as a point of reference in the review of filings.  Since loss trend rates based on industry experience are more credible, insurers are encouraged to use the guidelines or at least assign some credibility to them. Insurers can submit filings based on different trend rates, but must support their selections.

    The industry average expense ratio will be derived from the GISA Automobile Insurance Financial Information exhibit. The average will only serve as a point of reference. Reviews will consider an insurer's own expense history. Insurers must use their actual expense ratio. The Board will examine its validity and consider the variance from the industry average in cases where the expense ratio is notably higher than the industry average.

    The Board has established a profit provision of 7% of premium for basic and additional coverage combined. Filings where the target exceeds this profit provision must include justification for the selected provision.

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Capping

  1. Is an insurer required to cap the dislocation that arises through revisions to its rating program?

    No, capping is a voluntary tool that an insurer can use to limit dislocation.

  2. Can an insurer apply for longer capping periods?

    The majority of ratable changes should only require a 2-year capping measure.  However, the Board understands there may be situations where longer capping periods are desirable and may consider these situations where the insurer provides supporting evidence for the need.

  3. Given a rating program was previously approved, does the insurer need to re-file if it changes its capping procedure? Will the overall impact of the capping procedure be treated as a rate change, and be used to determine full filing vs. simplified filing?

    No, the capping change will not be treated as a rate change. The AIRB requires notification from the insurer for the change. The insurer must seek approval from the AIRB if it needs to extend its capping period. The indication is always calculated on an uncapped basis.

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Other

  1. AIRB policy states that insurers must adopt the latest CLEAR table for rate groups on their required 3rd year full filing. What if an insurer does not use CLEAR tables to set rate groups?

    An insurer has to file its method to determine rate groups with the Board on the first full or simplified filing. The insurer does not have to use CLEAR tables, as long as its method of developing rate group tables is actuarially sound and reasonable. The insurer is required to update the rate groups on its required 3rd year full filing regardless of the method used.

  2. Where can an insurer find the most updated assessment factor for Health Cost Recovery?

    Alberta Tax and Revenue Administration publishes the most recent assessment factor online. Insurers are encouraged to check the website to make sure their Health Cost Recovery loading is current.

  3. When can an insurer withdraw a filing?

    An insurer can withdraw a voluntary filing at any stage before its proposed effective date. The insurer needs to notify AIRB staff and explain the reason for withdrawal.

  4. The new Premiums Regulation took effect on July 1, 2014, but an insurer completed its analysis and was planning to submit its filing for additional coverage only, to the AIRB in August. Does it need to redo the analysis to comply with the new policies and procedures?

    It is acceptable to submit a simplified filing for basic and/or additional coverage if the proposed changes meet the exceptions outlined in Question 2 above. Otherwise, insurers must provide a full filing.

  5. Some variables that are not approved for basic coverage are being used for additional coverage. Can an insurer continue to apply those variables to additional coverage? Can an insurer extend the variable to basic coverage?

    Rating variables that have not been approved for rating programs as they pertain to basic coverage cannot be introduced for this coverage. Insurers that are currently using rating variables for additional coverage that are not acceptable for basic coverage can continue including them until a new policy is developed. Insurers can submit filings after July 1, 2014 to introduce rating variables for additional coverage which have not been approved for basic coverage. However, insurers should be aware of the risk that some variables may be eventually disallowed for all coverage.

  6. The filing guidelines state that insurers that limit their activity to experience and fleet rated risks are exempt from filing requirements. What are their obligations?

    Insurers that only write fleets or experience rated risks must submit a letter describing its automobile underwriting operations, i.e., the categories of vehicles that would be included, and attesting that it restricts its underwriting activity to fleet or experience rated risks and does not issue policies for individually rated risks. The insurer must reconfirm the nature of its underwriting activity on a bi-annual basis.

  7. Question added July 1, 2016:
    CLEAR filing


    Insurers should clearly indicate which version of the CLEAR tables they are adopting, and whether or not the insurer is adopting only the rate group assignment, differentials, or both.

    Insurers are not required to off-balance the premium impact due to the CLEAR update. However, the rate increase due to CLEAR update will be counted towards the 3% simplified filing increase threshold.

    In the case that the insurer does want to off-balance the premium impact, the revenue neutrality should be applied to each of the coverage that is affected. Since the Grid premium does not split into Third Party Liability and Accident Benefits coverage premiums, insurers whose AB coverage contains rate group as a rating variable are allowed to adjust TPL to keep the Grid rate unchanged.

  8. Question added July 1, 2016:
    New entrants filing


    Since new entrants usually do not have credible Alberta-only data to support the rating program, actuarial analysis will be waived if the insurer is proposing to adopt an existing rating program. Insurers are required to submit the following information for the Board to review:

    - history of the new company
    - underwriting manual
    - rating profiles
    - rating programs
    - source of the rating program (e.g. IAO, parent/sister company)

    If there is any change to the existing rating program, e.g. modifying sister company's base rates, the insurer is required to submit analysis to support the change.

    In the case of adopting IAO rating programs, insurers should contact the AIRB or IAO to make sure that the rating programs have been approved by the AIRB. Otherwise, a full filing for the particular IAO rating program is required.

  9. Question added July 1, 2016:
    Data requirement for Simplified filings


    The AIRB typically does not request analysis for simplified filings. However, in the case that a significant change to rating variable(s) or coverage rate level is proposed, the AIRB may ask for raw data or analysis from the previous full filing to support the changes. Insurers are encouraged to communicate with the office before submitting a filing to be better prepared.

If you have any further questions regarding filings, please contact the AIRB office at AIRB@gov.ab.ca.

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