Actuarial Notes

2024 Annual Statement on Market Conduct Public Report

By Canadian Council of Insurance Regulators · 2025

The Canadian Council of Insurance Regulators' public report on the 2024 data collected through the Annual Statement on Market Conduct (ASMC), published October 2025. The ASMC is an annual mandatory filing, introduced in 2017, that collects harmonized market conduct data from life and health (L&H) and property and casualty (P&C) insurers across Canada on the authority of each provincial and territorial regulator. The report gives a high-level overview of both sectors, notes year-over-year changes and emerging trends, and shows how the data supports CCIR members' oversight of the fair treatment of customers (FTC).

Introduction

  • Key Observations
    • Independent Distribution Channel: independent distribution contracts rose in both sectors (L&H to 481,052, P&C to 55,888); insurers audited independent agents and firms far less than direct/exclusive ones; the independent channel's share of L&H complaints rose from 45% (2022) to 61% (2024).
    • Commissions: commissions relative to premium are notably higher for Term Life than Whole and Universal Life, and higher in the independent channel.
    • Miscellaneous: applications declined by insurers have risen in all P&C classes since 2021; P&C administration-related complaints rose 195% year over year.

Background

  • How is Insurance Regulated in Canada?
    • OSFI oversees the solvency of federally incorporated insurers and foreign branches; provincial regulators supervise the market conduct of all insurers in their jurisdiction (Market Conduct Regulation).
  • What is the ASMC?
    • An annual mandatory filing developed by CCIR in 2017 to collect industry-wide data in a harmonized way; regulators may act on late filings.
  • What is CSOC?
    • The Cooperative Supervision Oversight Committee oversees ASMC collection and reporting and reviews the reporting requirements annually.
  • How Does CCIR Use the ASMC Data?
    • For a macro-level view of the industry, monitoring trends, risk assessments of classes, channels and insurers, key risk indicators for examinations, and validating the adoption of FTC principles.

Results from the 2024 ASMC Data

  • Filing Summary
    • L&H: 65 insurers required to file, 54 actively writing new business.
    • P&C: 213 insurers required to file, 148 actively writing new personal lines business.
  • Governance
    • FTC Implementation; Methods of Distribution; Customer Satisfaction Surveys
  • Policies
    • L&H Insurance Policies; P&C Insurance Policies
    • P&C Ratios: insurer-initiated non-renewals, customer-initiated cancellations, insurer-initiated cancellations and applications declined by insurer, each per policies in force, for Automobile, Property and Accident & Sickness, 2021–2024.
    • Internet Sales
  • Sales & Incentives
    • Commission Ratio: total commissions to total direct written premium.
    • Sales & Servicing Incentives
  • Claims
    • Claims Ratio: total claims to total direct written premium; Automobile had the highest P&C claims ratio in 2024, and Property rose 13.6% year over year.
    • Average Days To Final Payment And Claims Closed/Rejected Timeframe
    • Claims Rejection
  • Complaints
    • Complaint Examination; Complaints Handling; Life & Health; Property & Casualty

Conclusion

  • Next Steps
    • Regulators will keep using ASMC data for thematic reviews, questionnaires and cooperative initiatives across jurisdictions.

Appendix

  • Appendix A - Claim Rejection Reasons for L&H Insurers by the Company Size
  • Appendix B – Claim Rejection Reasons for P&C Insurers by the Company Size

Related readings

  • CCIR Instructions — CCIR's harmonized annual P&C insurance return

Sources