The U.S. Department of the Treasury has announced the 2026 data call for the Terrorism Risk Insurance Program, known as TRIP. This directive, published in the Federal Register on March 25, 2026, requires participating insurers to submit information on their terrorism risk insurance activities for the period from January 1, 2025, to December 31, 2025. The data collection aims to fulfill statutory obligations under the Terrorism Risk Insurance Act of 2002, as amended, ensuring the program's role in stabilizing the commercial property and casualty insurance market against terrorism risks. By mandating this information, Treasury seeks to evaluate the program's effectiveness, with a report due to Congress by June 30, 2026. This development underscores the ongoing federal effort to monitor and support terrorism risk coverage, especially as the program's current authorization extends only until December 31, 2027.
Background of the Terrorism Risk Insurance Program
The Terrorism Risk Insurance Act, or TRIA, was enacted in 2002 following the September 11, 2001, terrorist attacks, which caused significant disruptions in the insurance market. The law established TRIP within the Treasury Department to provide a federal backstop for terrorism-related claims, encouraging private insurers to offer coverage while limiting their exposure to catastrophic losses. Under TRIA, the federal government shares losses with insurers above certain thresholds, known as the program trigger, which for 2025 stands at $200 million.
TRIP has been reauthorized several times, most recently through the Terrorism Risk Insurance Program Reauthorization Act of 2019, extending it to 2027. Section 104(h)(1) of TRIA requires the Secretary of the Treasury to collect annual data from participating insurers to assess the program's impact on insurance availability and affordability. Treasury regulations at 31 CFR 50.51 and 50.54 further outline this requirement. The Federal Insurance Office, or FIO, assists in administering the program, including conducting these data calls and preparing required reports. A biennial effectiveness report, mandated by Section 104(h)(2) of TRIA, analyzes the program's overall performance and must be submitted to Congress.
Key players include the Treasury Department, state insurance regulators, the National Association of Insurance Commissioners (NAIC), and industry groups such as the National Council on Compensation Insurance (NCCI). These entities collaborate to minimize reporting burdens while gathering comprehensive data. Historical precedents, such as the program's initial implementation post-9/11 and subsequent reauthorizations, highlight political debates over federal involvement in insurance markets, with perspectives ranging from industry support for stability to concerns about long-term taxpayer exposure.
Details of the 2026 Data Call Process
The 2026 data call targets insurers writing commercial property and casualty insurance in TRIP-eligible lines, with submissions due by May 15, 2026. Insurers must register at https://tripsection111data.com and submit data via a secure portal. This process, approved under OMB Control Number 1505-0257, ensures compliance with the Paperwork Reduction Act.
Treasury coordinates with state regulators and the NAIC using consolidated reporting templates first introduced in 2018. This approach reduces duplication, as insurers report on a group basis if affiliated, or individually otherwise. For workers' compensation data, Treasury partners with NCCI, the California Workers' Compensation Insurance Rating Bureau, and the New York Compensation Insurance Rating Board to pre-fill relevant sections, easing the burden on insurers. As noted in the Federal Register notice, 'The data aggregator used by Treasury will provide such insurers with reporting templates that do not require them to report this workers' compensation data.'
Training webinars are scheduled for April 2 and 3, 2026, to guide insurers on the templates, with recordings available on Treasury's website. Supplemental resources, including ZIP code listings for geographic exposures and hypothetical reporting scenarios, are also provided online.
Reporting Templates and Categories of Insurers
The data call employs four templates tailored to insurer types: Small Insurers, Non-Small Insurers, Captive Insurers, and Alien Surplus Lines Insurers. There are no material changes from the 2025 templates, maintaining consistency. Small Insurers, defined under 31 CFR 50.4(z) as those with 2024 policyholder surplus and TRIP-eligible direct earned premiums below $1 billion each, use a simplified form. Those with less than $10 million in 2025 TRIP-eligible premiums are exempt, except for captives and alien surplus lines insurers.
Non-Small Insurers, with surplus or premiums at or above $1 billion, complete a more detailed template, including modeled loss scenarios on the Reinsurance Worksheet. Captive Insurers, licensed under state captive laws per 31 CFR 50.4(g), must report unless they provided no TRIP-subject terrorism coverage. Alien Surplus Lines Insurers, listed on the NAIC Quarterly Listing per 31 CFR 50.4(o)(1)(i)(B), report separately unless part of a larger group.
These categories reflect TRIA's aim to capture diverse market segments. For instance, the notice specifies that small insurers complete a separate Reinsurance Worksheet without modeled loss questions, acknowledging their limited capacity.
Implications and Perspectives
The data call's short-term implications include administrative burdens for insurers, though coordination efforts mitigate this. Collected data will inform the 2026 effectiveness report, potentially influencing policy discussions on affordability and market stability. Long-term, as TRIP approaches its 2027 expiration, the report could shape reauthorization debates. Industry stakeholders view the program as essential for risk management, citing post-9/11 market failures, while critics argue it distorts private markets and burdens taxpayers.
Legal precedents, such as court rulings on TRIA interpretations in cases like those involving program certifications, emphasize the need for accurate data to avoid disputes. Political forces, including congressional oversight, highlight bipartisan support for extensions but ongoing debates over program triggers and deductibles.
In conclusion, the 2026 data call represents a critical step in TRIP's administration, ensuring data-driven evaluations amid evolving terrorism risks. Potential next steps include Treasury's analysis for the June 2026 report, which may prompt legislative reviews. Ongoing challenges involve balancing federal support with private market development, while debates persist on extending the program beyond 2027 or introducing reforms to enhance resilience.
