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Navigating VM-22: Key considerations in data, technology and processes


In brief
  • VM-22 is the most recent development in principle-based reserving frameworks for non-variable annuity contracts.
  • The framework’s stochastic modeling substantially impacts data management, computations and technology supporting US statutory valuation and forecasts.
  • Companies must evaluate their VM-22 adoption process and assess how well they’re equipped to support the new requirements ahead of the 2026 effective date.

The National Association of Insurance Commissioners (NAIC) Valuation Manual (VM)-22 proposes significant changes to the calculation of statutory reserve requirements for non-variable annuity contracts issued on or after January 1, 2029 (and is optional for non-variable annuity contracts issued on or after January 1, 2026). Companies must recognize the impact VM-22 will have on data, technology infrastructure and operating processes. This proposed regulatory change is more than a compliance checkbox — it’s a transformative event that demands careful consideration and proactive planning from business and technology teams.

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Summary of VM-22 methodology change

VM-22 represents a shift toward a proposed principle-based valuation framework, moving away from the traditional, formulaic commissioners’ annuity reserve valuation method (CARVM). This new methodology requires stochastic projections of both assets and liabilities across numerous scenarios, using company-specific assumptions with prudent margins. Stochastic Reserves are measured using cumulative tail expectations above 70% (CTE70).

 

VM-22 also introduces the additional standard projection amount (ASPA), a proposed disclosure item for the stochastic reserve to account for outlier company assumptions and offers a deterministic certification option (DCO) for non-variable annuity products that are not sensitive to economic conditions.

 

Field testing

The VM-22 framework is undergoing field testing to quantify its impact and review results from industry participants. This process aims to assess key design decisions, including aggregation, reinvestment guardrail mix, the stochastic exclusion ratio test (SERT), and the ASPA. As of early 2025, the American Academy of Actuaries and Ernst & Young LLP (EY US) have independently aggregated, clarified and aligned the VM-22 field test results. EY US also presented a preliminary summary of field test results to the Life Actuarial Task Force (LATF) and the VM-22 subgroup.

 

Implications of VM-22 changes to data and technology

VM-22 will significantly impact reserving requirements and potentially affect capital levels. While valuation actuaries focus on interpreting new methodologies, modeling actuaries are responsible for implementing those changes through model development and execution. Companies should proactively engage with their technology teams and advisors to assess VM-22's potential impacts on data management, technology infrastructure and business processes.

 

Conclusion

Insurance companies must address several critical areas to prepare for VM-22 adoption, including the actuarial, finance and investment functions, as well as the supporting data and technology infrastructure. VM-22 will impose increased demands on these platforms and operating models due to more complex calculations, larger data volumes and the potential need for more analysis to explain results movements and impacts.

 

Proactively engage with your teams today to assess your readiness for VM-22. Develop a tailored strategy to achieve and monitor compliance and operational efficiency. Start planning now to both stay ahead of the curve and mitigate risks effectively.

This article is co-authored by Mikkel Matsoukas, Insurance and Actuarial Advisory Services, Ernst & Young LLP and Sida Wen, Insurance and Actuarial Advisory Services, Ernst & Young LLP.

Summary 

Depending on where you are in your journey to prepare for VM-22, take a comprehensive look at your current statutory reporting processes for non-variable annuity products. Identify areas where your processes and technology may be challenged by VM-22 requirements and explore opportunities for improvement or transformation.

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