Washington TAA 2026-01 reaffirms the Office of the Insurance Commissioner 2015 guidance on price optimization, making clear that using statistical analysis to estimate an insured price sensitivity and basing premiums on that sensitivity, when unrelated to expected costs, is unfairly discriminatory under Washington law. The advisory cites RCW 48.19.020 (rates must not be excessive, inadequate, or unfairly discriminatory) and WAC 284-24-065(1) (rates must be actuarially sound estimates of expected future costs). Practices such as charging different premiums to insureds with identical risk profiles based on willingness to pay, or imposing loyalty penalties, are explicitly condemned. Rates found unlawfully discriminatory will not be approved. P&C insurers operating in Washington should audit their pricing models for compliance, though this advisory reaffirms existing law rather than establishing new requirements.
Source: https://www.insurance.wa.gov/sites/default/files/2026-10/technical-assistance-advisories-2026-01.pdf