NAIC Analysis Identifies and Categorizes Insurer Private Credit Investments
Report offers detailed breakdown of how private credit is reflected on insurer balance sheets, defining and quantifying key areas of regulator focus
The National Association of Insurance Commissioners’ (NAIC) Private Credit Analysis of the U.S. Insurance Industry report draws on U.S. insurer investment data as of year-end 2025 to identify and categorize investment holdings across distinct private credit categories, establishing a clearer framework for regulators, policymakers, and the public to understand where risk and complexity reside within this market.
“Taking a data-centric approach, state insurance regulators are continuing to evolve regulatory frameworks alongside insurers’ changing investment strategies, ownership structures, and risk-transfer arrangements,” said Virginia Insurance Commissioner and NAIC President Scott White. “This report is a prime example of how the NAIC supports its Members as state insurance regulators oversee increasingly complex investments and asset structures.”
According to the report, as of year-end 2025, the entire U.S. insurance industry held $1.21 trillion in assets that fall under a broad and expansive definition of private credit, representing approximately 13% of cash and invested assets. Critically, of this $1.2 trillion, more than half was held in assets with more straightforward credit risks and structures (private placement bonds, bank loans, and middle-market collateralized loan obligations). The report notes that these assets technically fall within a much broader definition of private credit. They not only reflect asset classes that U.S. insurers have invested in for decades, but they also represent assets that regulators have a long history of monitoring.
The report defines NAIC analysts’ primary focus as private credit holdings that may introduce additional risks through greater structural complexity and/or underlying exposure to alternative assets (privately rated bonds, business development companies, and private credit funds). As of year-end 2025, U.S. insurers’ investments in these assets totaled $544 billion. This was less than half of all insurers’ private credit holdings and represented approximately 6% of cash and invested assets and 9% of total bond holdings.
Looking ahead, the NAIC expects its understanding of insurers' private credit allocations to sharpen further as enhanced reporting disclosures that were adopted in 2026 are included in year-end 2026 annual statement filings, improving the identification and classification of private credit investments and refining exposure analyses.
Resources
Private Credit and Insurance: A Data-Driven View from State Regulators
About the National Association of Insurance Commissioners
As part of our state-based system of insurance regulation in the United States, the National Association of Insurance Commissioners (NAIC) provides expertise, data, and analysis for insurance commissioners to effectively regulate the industry and protect consumers. The U.S. standard-setting organization is governed by the chief insurance regulators from the 50 states, the District of Columbia and five U.S. territories. State insurance regulators, through the NAIC, establish standards and best practices, conduct peer reviews, and coordinate regulatory oversight. NAIC staff supports these efforts and represents the collective views of state regulators domestically and internationally.