Indiana Insurers Reporting Ownership Information Requirements

IN Insurance Bulletins

Published June 10th, 2025

Detected March 19th, 2026

Summary

The Indiana Department of Insurance issued Bulletin 278 to notify insurers, third-party administrators, and pharmacy benefit managers of new ownership information reporting requirements effective July 1, 2025. Entities must report individuals or entities with at least a 5% ownership interest, controlling interest, or private equity partner interest.

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What changed

The Indiana Department of Insurance (IDOI) has issued Bulletin 278, mandating that all insurers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs) doing business in Indiana must begin reporting detailed ownership information starting July 1, 2025. This new requirement, stemming from Public Law 239-2025 (HEA 1666), mandates the disclosure of names, business addresses, website information, applicable identification numbers (NPI, TIN, EIN, CCN, NAIC, or state license ID), and ownership stakes for any person or entity holding at least a 5% ownership interest, a controlling interest, or a private equity partner interest. Social Security numbers are explicitly prohibited from these reports.

Regulated entities must prepare to compile and submit this ownership data by July 1, 2025. Failure to comply may result in daily fines of $1,000, with a grace period offered for the initial 2025 reporting deadline while submission methods are finalized. However, late reports in 2026 are subject to fines. Compliance officers should ensure their organizations have processes in place to gather and report this information accurately and on time to avoid penalties and disciplinary actions. Further details on the submission format will be provided in a subsequent bulletin.

What to do next

Identify all individuals/entities with ownership interests (>=5%, controlling, or private equity) in the insurer, TPA, or PBM.
Gather required identifying information (name, business address, website, applicable IDs) for each identified owner.
Determine ownership stake percentage for each identified owner and prepare report for submission by July 1, 2025.

Penalties

Fines of one thousand dollars ($1,000) per day for past due reports; potential disciplinary action for repeat violations.

Source document (simplified)

Indiana Department oflnsurance June I 0, Bulletin 278 REPORTING OF OWNERSHIP INFORMATION This bulletin is directed to all insurers, third party administrators ("TP As"), and pharmacy benefit managers ("PB Ms"), as defined in Public Law 239-2025 (HEA 1666), doing business in Indiana. The purpose of this bulletin is to notify insurers, TPAs, and PBMs of new repmiing requirements set fmih in Pub. L. 239-2025. Pursuant to Pub. L. 239-2025, beginning July I, 2025, and each July 1 thereafter, each insurer, TP A, and PBM doing business in Indiana shall file with the Department a repo1i that includes the following information: (1) The name of each person or entity that has: (A) an ownership interest ofat least five percent (5%); (B) a controlling interest; or (C) an interest as a private equity partner; in the insurer, TP A, or PBM. (2) The business address of each person or entity identified in item (I), above. The business address must include a: (A) building number; (B) street name; (C) city name; (D) ZIP code; and (E) country name. The business address may not include a post office box number. (3) The business website, if applicable, ofeach person or entity identified in item (I), above. (4) Any ofthe following identification numbers, if applicable, for a person or entity identified under item (I), above: (A) National provider identifier (NPI). (B) Taxpayer identification number (TIN). (C) Employer identification number (EIN). (D) CMS certification number (CCN). (E) National Association oflnsurance Commissioners (NAIC) identification number. (F) A personal identification number associated with a license issued by the Department. (5) The ownership stake ofeach person or entity identified under item (I), above.

A report provided under IC 27-l-4.5-5(a) may not include Social Security numbers of any individual. The Department may assess a fine of one thousand dollars ($1,000) per day for which a report is past due and the Department may take disciplinary action for repeat violations. The Department is providing a grace period for IC 27-1-4.5 reports due beginning July I, 2025, while the form and manner for submission is established but may assess a fine pursuant to IC 27-1-4.5- 7 for late reports in 2026. This is the first of two (2) bulletins that will be issued notifying insurers, TP As, and PBMs of these new reporting requirements. The second bulletin will provide further details regarding form and manner ofthe required reports. Questions regarding this bulletin should be directed to compliance@idoi.in.gov. INDIANA DEPARTMENT Of INSURANCE nsurance