Compliance Corner
What’s changed and why it matters.
January 05, 2026
January 05, 2026
Compliance Corner is our regular snapshot of regulatory changes that matter to licensing, compliance, and operations teams right now.
Rather than commentary or speculation, we focus on what has changed, when it takes effect, and what it means for execution. This edition covers recent updates across cybersecurity, producer licensing, education requirements, and background application standards, with effective dates ranging from late 2025 into early 2026. Use this as a reference point. Flag what applies to your organization. As always, we’ll continue tracking implementation timelines and downstream impacts as these rules move from paper to practice.
As of November 1st, Final NYDFS Cybersecurity Rules took Effect Requiring MFA
Back in 2023, New York Department of Financial Services amended its cybersecurity regulation 23 NYCRR Part 500 with new requirements starting in November 2023 and going through November 2025.
The final rule took effect on November 1, 2025, which requires Covered Entities from the Small Business, Standard, and Class A categories to comply with enhanced multi-factor authentication requirements.
Small Business and their affiliates that meet all these criteria for the last three years qualify for the limited “small business” exemption:
- Fewer than twenty employees and independent contractors,
- Less than $7.5 million in gross annual revenue in each of the last two fiscal years from its New York business operations, or
- less than $15 million in year-end total assets
Even with the limited exemption, small businesses will still need to implement MFA for:
- Remote Access: Any login from outside the entity’s network
- Third-Party Apps: Cloud services or vendors accessing sensitive data
- Privileged Accounts: Admin, superuser, or other high-level accounts (excluding non-interactive service accounts)
Maine New Temporary Apprentice Insurance Producer License Checklist
Effective: January 1, 2026
Term: Up to 180 days | Exam: Not required
Applicant Eligibility:
- At least 18 years old
- Maine resident at application and throughout apprenticeship
- Employed by a licensed Maine resident producer (sponsor)
- Sponsor certifies supervision and assumes responsibility
- Insurance producer license application submitted
- Meets all producer requirements except exam
- Has never held or been denied a producer or apprentice license (Maine or any jurisdiction)
- Temporary license fee and applicable application fees paid
Apprentice Limitations:
- Activities limited to those requiring a producer license for Maine risks only
- Activities limited to sponsor’s authorized lines
- May not act as insurer agent unless appointed
- Must obtain a producer license within 180 days
Prohibited Activities:
- Life Insurance
- Annuities
- LTC
- ACA-related activities
Sponsor Requirements:
- Sponsor application completed
- Maine producer license in good standing for at least 1 year
- No license restrictions, probation, or disciplinary reporting obligations
- Assumes full legal responsibility for apprentice’s acts
- No more than 2 active apprentices per calendar year
- Complies with all superintendent-established requirements
Reporting & Oversight:
- Apprentice and sponsor report actions as required under §1420-P
- Superintendent may limit authority or revoke license if public interest is endangered
Termination Notice:
Sponsor and apprentice notify superintendent within 5 business days if:
- Employment ends, or
- Sponsorship terminates before 180 days
California repeals the 20 hours of pre-licensing requirement Effective January 1, 2026
What’s Gone:
The mandatory 20 hours of line-specific pre-licensing education for producer license applicants for property, casualty, commercial lines, personal lines, limited line automobile, life, and accident and health or sickness.
What Stays:
- Passing the state licensing exam is still required. Check out the Licensing Examination Objectives
- Submit fingerprints before submitting your license application.
- A mandatory 12-hour course on California Insurance Code and Ethics remains in place.
- Bail agents and Public Adjusters 20-hours of pre-licensing education is required.
2026 Uniform Background Question Updates
NAIC approved updates to the uniform application in December 2024. All 54 jurisdictions have agreed to the updated elements ensuring nationwide consistency.
Key Enhancements:
- Clarified attestation language and background question language
- Citizenship question added to individual renewal applications
- FINRA CRD# added to renewal applications
- Updated terminology and clearer instructions
Industry and state systems will need to update their processes to support the new electronic application format. Production is expected to be early Q2 of 2026.
We’ll continue monitoring these changes as additional guidance is released and state systems adjust. If any of these updates affect your licensing, compliance, or operational workflows, it’s worth validating timelines and controls now, especially where requirements phase in through 2026.
Questions about how these updates affect your licensing or compliance workflows?
We can help you assess what applies, what’s changing, and where to focus first.
With more than 25 years in the insurance industry, Wendy Boe specializes in enterprise risk management, corporate governance, and legal & compliance operations. Her career spans roles as a direct-writing agent, independent agency owner, and compliance consultant for adjusting firms, MGAs, and alternative insurance markets. She is passionate about mentorship and education, has taught CE and pre-licensing programs, and is currently pursuing a Juris Doctorate. Wendy holds CIC, FCLS, and CRM designations.