Q1 2026 Deep Dive: Late Filing Premium in Texas
The trend is unmistakable: late filing premiums increased significantly since mid-2024, rising from approximately $50 million per month in early 2022 to peaks exceeding $100 million per month in 2025. This upward trajectory raises an obvious question: what’s driving it?
Premium Stratification (Late vs On-Time Policies)
Another way to examine the relationship between late policies and their premium volume is by ascertaining whether a policy is late and then placing it in a bucket based on its premium volume. The stratification below shows the percentage of total on-time policies and the percentage of total late policies that are in each premium bucket.
A pattern emerges when comparing the premium distribution of late versus on-time policies. Late policies are disproportionately concentrated in higher premium ranges. Policies with premiums exceeding $10,000 constitute nearly 32% of all late filings, compared to 20% of on-time filings. This increase suggests that higher-value policies face unique challenges in meeting filing deadlines, whether due to increased underwriting complexity, more extensive documentation requirements, or multi-party approval processes. Conversely, smaller premium policies (under $2,500) are more likely to be filed on time, representing 45.5% of on-time policies but only 37.6% of late policies. This size-based disparity has important implications for premium reporting accuracy, as late filing of high-premium policies creates proportionally larger distortions in reported monthly totals.
Reporting Period vs Written Period
A key driver of premium distortion is the gap between when a policy is written and when it was reported to SLTX. For example, a policy written in January but not filed until March contributes premium to the March totals even though the underlying risk attaches earlier. These timing differences accumulate quickly in periods of elevated late filing activity.
On average, 29.9% of premium that is reported in a given month is attributable to items written in the same month. Expanding the window, however, shows that, on average, 85.4% of premium reported in a month is attributable to items written within 90 days (both before and after). Both of these trends are consistent month to month as well.
Because of this inherent lag, month-to-month comparisons can be noisy, especially when late filing volumes increase. For meaningful trend detection, longer multi-month or quarterly perspectives offer a more reliable view of true market behavior.
So, Why Are Late Filing Premiums Increasing?
Late filing premiums have risen faster than overall market growth, indicating that this trend reflects more than just a larger marketplace. The increase is driven by a combination of factors: a higher share of large-premium policies being filed late, persistent seasonal workflow pressures, and differences in filing automation across agencies.
The following sections evaluate each potential factor.
Late Filing Premium vs Overall Premium
A simple explanation for the recent increase in late filing premiums is that overall premiums are increasing. However, while it is true that SLTX has recorded an ongoing trend of increasing premiums, normalizing by total reported premium reveals that late premiums have grown not just in dollar terms but also as a percentage of total market activity.
The chart above shows that late premium as a percentage of total premium has increased from approximately 3-8% in 2022 to peaks of 8-13% in 2024-2025. This finding indicates that the growth in late filing premiums cannot be attributed solely to overall market expansion. Instead, there has been a genuine deterioration in filing timeliness relative to market size. The upward trend in the percentage suggests systemic challenges that are affecting the Texas surplus lines market.
Late Filing Premium vs Late Policies
While premiums reported to SLTX have increased steadily for almost a decade, the number of policies reported have also reflected growth more recently. Therefore, another natural assumption might be that late filing premiums are increasing because the number of late filings are increasing. However, as reflected in the chart below, this assumption does not bear out in the data.
The number of policies filed late has shown a stable trend since 2022, from approximately 1,000-2,000 late policies per month to 800-2,000 in 2024 and 2025. Outside of a handful of outlier months in 2023, the trend in late filing counts has not experienced the same trajectory as late premiums.
Seasonal Patterns
In addition to long-term growth, late filing premiums follow clear seasonal rhythms. Understanding these month-to-month patterns provides important context for interpreting peak periods of late premium activity.
August through December consistently show elevated late filing premiums, likely reflecting year-end processing backlogs. The boxplots show median late premiums and their variability across months, while the individual points colored by year demonstrate that 2024, 2025, and 2026 (orange, blue-gray, and green points) consistently sit above earlier years across nearly all months. This suggests that while seasonality plays a role, the year-over-year increase is the dominant trend. The months of January through April appear particularly volatile, with the widest ranges in late premium amounts due to unusually high late filing premiums in 2025. Understanding these seasonal patterns can help SLTX and the agency and brokerage community anticipate resource needs and implement targeted interventions during high-risk periods.
Filing Method
Filing method plays a significant role in timeliness. Data Entry submissions, which involve agents mailing documents to SLTX for manual entry, have the highest late premium percentage at approximately 25.4%. This association contrasts with the overall distribution of premiums by filing method, where Data Entry and API filings accounted for 0.6% and 49.4%, respectively, of all premiums over the same time period. Because mailed filings are considered “reported” upon SLTX receipt, all delays are associated with document preparation before mailing.
In contrast, API submissions, which are typically automated, high-volume filings from large brokerages or MGAs, demonstrate the most consistent on-time filing performance. The superior performance of API submissions suggests that automation and integration with agency management systems substantially reduces late filing risk. This finding highlights the operational advantages of automation and suggests that agencies or brokerages handling high volumes could benefit from transitioning to API submission where feasible.
Concentration of Late Filing Premiums Amongst Agencies/Brokerages
Late filing premiums are highly concentrated among a small group of agencies. Since 2022, just 7% of agencies have accounted for 92% of all late-reported premium.
This concentration suggests that late filing behavior is often driven less by broad, market-wide challenges and more by workflow, process, or system-specific issues at the individual agency level.
Understanding where late premium volume is concentrated allows SLTX to approach the issue with greater precision. Rather than applying a one-size-fits-all strategy, the data highlights the importance of working directly with the agencies most affected, identifying the specific procedural or technical barriers they face, and tailoring support to address their unique challenges.
Monthly vs Annual Late Filing Report
While this analysis focuses on late filing premiums in the aggregate, it is worth drawing attention to a distinction that has direct implications for every reporting agent: the difference between the monthly Late Filing Report and the annual Late Filing Report.
Each month, SLTX distributes a Late Filing Report for each agency in SMART that captures all policies currently flagged as late. This report is not final; it represents a snapshot in time. Agents who actively review their monthly report have a meaningful window to identify filings that may warrant a closer look before the annual cutoff.
After the monthly late filing report is distributed, each agency has the right to dispute any filings on their report, and TDI holds final authority over all dispute determinations. It is worth noting that, when submitting disputes, agents should focus their attention on filings where a genuine procedural or factual basis for review exists rather than treating the process as a routine appeals mechanism.
That said, identifying legitimate discrepancies early, before the annual report is finalized, creates the best opportunity for accurate representation of an agency’s filing record. Given that late filing premiums are concentrated among a small number of agencies, even a focused and targeted review effort by those agencies could result in a meaningful reduction in the premium ultimately reflected on the annual submission.
SLTX’s TechSupport team is available to help agents understand their monthly report, identify patterns in their flagged filings, and, where appropriate, assist in communicating substantive disputes to TDI ahead of the annual cutoff.
Conclusion
Late filing premiums are increasing due to a mix of timing behavior, workflow complexity, and challenges unique to individual agencies. The increase in late filing premiums is also separate and distinct from overall market trends. Additionally, the E&S industry sits at a complex intersection of business processes, policy dynamics, and underwriting challenges. This makes late premiums a nuanced operational issue rather than a simple compliance challenge. There is no single root cause and likewise, no single universal solution. Each agency’s filing behavior is shaped by its own systems, workflows, and constraints, meaning that reducing late filing premiums requires individualized solutions rather than broad market-wide prescriptions.
For agencies seeking to better understand their filing patterns or identify opportunities for improvement, SLTX’s TechSupport team is the best resource. They can provide tailored guidance, investigate system-specific issues, and help agencies streamline their processes in ways that support more timely filing and more accurate reporting.