Oregon's wildfire insurance transparency bill died in Rules
Oregon's wildfire insurance transparency bill died in Rules
2026-09-15 · Oregon · Legislation · Did not pass
Oregon's only 2026 attempt to regulate how insurers model wildfire risk passed its policy committee unanimously and then died in Senate Rules without a floor vote. Senate Bill 1540 ended with the session on March 6, 2026.1
What it would have done
Three things: required insurers to disclose their wildfire risk-modeling methods to the Department of Consumer and Business Services; created incentives for property-level and community-level mitigation; and given the insurance commissioner authority to disapprove rate filings containing wildfire risk models.
That third element is the one the industry fought. It would have moved proprietary catastrophe models from unreviewable inputs into reviewable ones.
Why it mattered to associations specifically
Because of what Oregon did the year before. Senate Bill 83 repealed the statewide wildfire hazard map in July 2025 — and the map was the only thing insurers were statutorily forbidden to use.
ORS 742.278 survives untouched: “An insurance company may not use a map published by an agency of this state that identifies areas of wildfire risk or exposure as a basis for: (1) Canceling or declining to renew a homeowner insurance policy; or (2) Increasing a premium for a homeowner insurance policy.”2
The Division of Financial Regulation states the consequence plainly: repealing the map “does not change the customary practice of insurers using their own proprietary models when making insurance decisions.”
So Oregon has a statute prohibiting the use of a map that no longer exists, and no statute reaching the private models that are actually used. Senate Bill 1540 was the proposal to close that gap.
The industry position
Northwest Insurance Council president Kenton Brine called it too much for a 35-day short session: “That puts a lot of 'hope' on the data side but imposes significant and costly mandates on insurers.”3
What the state's own data shows
The Division of Financial Regulation presented Oregon homeowners insurance data to the Legislature during the 2025 interim, and the findings are more measured than the market narrative suggests.4
There are “Over 100 companies” writing homeowners insurance in Oregon. “FAIR Plan (market of last resort) numbers remain relatively stable.” “Nonrenewals remain relatively steady” between 2018 and 2022. And — counterintuitively — “The leading driver of nonrenewals and cancellations is nonpayment.”
What is rising is price: “Average premium is growing at a rate higher than the consumer price index (CPI),” and “Total losses and average losses per claim are trending upward, with a spike in 2020 driven by wildfires.”
The data behind all of this covers insurers making up 80 percent of Oregon's homeowners business, through 2022. The Division's next data call is to cover 2023 to 2025 and 100 percent of the market.
The number that is being misreported
The Division's reinsurance study for calendar years 2018 to 2024 found:
“Premium increased at a higher rate (205 percent) than coverage purchased (90 percent). This is also reflected in the 38 percent decrease in coverage per $1,000 of premium from 2018 to 2024. The most significant change in all values took place between 2020 and 2021.”
That 205 percent is catastrophe reinsurance treaty premium paid by insurers. It is not a homeowner premium increase, and several trade write-ups have reported it as one. The honest framing is that Oregon carriers paid 205 percent more for 90 percent more reinsurance coverage — an upstream cost that flows into master-policy pricing but is not itself a consumer rate.
The study also found that all respondents identified affordability as a factor in placing reinsurance treaties since 2018, that 75 percent said obtaining coverage was harder or significantly harder in 2024 than 2018, and that 56 percent identified the number of available options as a leading factor.
What did pass instead
Two things an Oregon board can actually use.
House Bill 2563 (2025), operative September 1, 2026, requires “a clear and reasonable explanation of the reasons for any increase in the premium amount for a qualified policy upon renewal,” including up to four significant contributing factors. On the next master-policy renewal with an increase, that explanation is a statutory entitlement.
ORS 742.277, surviving from Senate Bill 82 in 2023, defines “wildfire risk mitigation action” to include “A community-level action, such as receiving recognition as a Firewise USA Site in Good Standing or recognition from a similar entity or participating in community risk reduction programs established by the State Fire Marshal.” An association-wide Firewise designation is a statutorily named mitigation action, and insurers must reflect mitigation in rating and underwriting — though the statute leaves flexibility in how that consideration is expressed.
Our Oregon insurance requirements page covers what an association's documents and statute oblige it to carry.
What the Division is doing without the bill
Its published rulemaking calendar for 2026 contains nothing on homeowners insurance, wildfire, or nonrenewals — the listed items are ground ambulance balance billing, network adequacy, standard health plans, producer licence fees, prescription drug price transparency, prosthetic and orthotic devices, the reinsurance program and a bank tax credit.
The Division's instrument of choice in this period has been the emergency order, not the rule: the July 31, 2026 wildfire emergency order suspending cancellations and nonrenewals across all property and casualty lines in affected ZIP codes, extended on August 26 and running to approximately September 29, 2026.
Its own stated work plan is to refresh data for 2023 to 2025, implement the 2025-session initiatives, and “Investigate FAIR plan and other state solutions.” That last item is the tell.
What to watch next
The FAIR Plan question, and the 2027 session. Oregon's FAIR Plan covers one-to-four family dwellings to $600,000 on an actual cash value basis and commercial property to $1,000,000 for all coverage parts — which is not a backstop a condominium association can use. If the Division's investigation produces a proposal, the 2027 long session is where it lands, with more room than 35 days allowed.
Related Oregon HOA Topics
- Oregon wildfire insurance reform dies after industry pushback, Insurance Business ↩
- ORS 742.277 and ORS 742.278, Oregon insurance code ↩
- Wildfire insurance, Oregon Division of Financial Regulation ↩
- Oregon homeowners' insurance update — Division of Financial Regulation presentation to the Legislature, 2025 interim ↩
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