Last updated: April 28, 2026 | By Elizabeth Prescott
- NAIC’s revised Actuarial Guideline XLIX-A (AG 49-A) took effect for fixed indexed annuity (FIA) policies sold on or after April 1, 2026.
- The update tightens what carriers can show in basic and supplemental illustrations, including limits on historical index information and backcasted performance.
- Regulators acted after observing FIA disclosures suggesting annual returns of 10% to 25% for multiple years – figures most products cannot realistically deliver.
- For buyers, the change means new FIA illustrations should be more conservative and easier to compare across carriers.
A revised version of NAIC Actuarial Guideline XLIX-A, the rule that governs how fixed indexed annuity (FIA) sales illustrations are constructed, took effect for new policies sold on or after April 1, 2026. The change was adopted by the NAIC’s Life Insurance and Annuities (A) Committee on November 21, 2025 and applies prospectively only – existing FIA contracts and illustrations issued before April 1 are unaffected.
The guideline sits at the center of one of the longest-running disputes in retirement product regulation: how aggressively carriers can advertise hypothetical FIA returns to consumers who may not understand caps, participation rates, and spreads.
What Changed on April 1, 2026
The revised AG 49-A clarifies sections 7.B and 7.C of the original guideline, which govern the use of historical index data in illustrations.
For FIA policies sold on or after April 1, 2026:
- Neither the basic illustration nor the supplemental illustration may include certain historical index information that produces a hypothetical annualized credited rate above the maximum illustrated rate.
- Basic illustrations must include a disclosure noting that hypothetical annualized rates of indexed credits use current index account parameters – not historical caps or par rates that may no longer be available.
- Backcasted performance using stale parameters is restricted.
In plain English: a carrier can no longer pull a 20-year stretch of S&P 500 data, apply today’s cap, ignore the years when the cap was lower, and present the resulting figure as a realistic outlook.
Why Regulators Acted
State insurance regulators reported seeing FIA marketing material and producer illustrations that implied annual returns of 10% to 25% for several consecutive years. Those figures are mathematically possible in isolated periods but cannot be sustained under the cap, spread, and participation-rate structures that govern modern FIA contracts.
The NAIC’s concern was that consumers – particularly retirees comparing an FIA to a MYGA or a bank CD – were forming unrealistic expectations of guaranteed-style upside that the products were never designed to deliver.
What This Means for Buyers
If you are shopping for a fixed indexed annuity in 2026, three things to expect:
- Lower illustrated rates. Hypothetical credited rates on new illustrations should be more conservative than what you may have seen in 2024 or 2025 marketing material. This is a feature, not a bug – the older numbers were often unachievable.
- More uniform comparisons. Because all carriers must use current index parameters and disclose them, side-by-side FIA quotes from different companies should be easier to evaluate. Look at the cap, par rate, spread, and current illustrated rate together.
- No retroactive change to in-force contracts. If you already own an FIA, the guideline change does not affect your existing contract terms or your renewal rates. It governs how new illustrations are constructed.
What This Means for FIA Carriers
Major FIA writers – Athene, Allianz, Corebridge, Nationwide, F&G, Sammons, North American, and others – have been updating their illustration software since late 2025 to comply. Carriers that relied heavily on aggressive backcasted illustrations as a sales differentiator will see the largest competitive impact. Carriers that already produced conservative, current-parameter illustrations will see relatively little change.
For context on how FIAs work today, see our pillar guide on what is a fixed index annuity and our 2026 ranking of the best fixed annuity companies.
The Bigger Picture: Illustration Discipline
AG 49-A is the latest in a series of NAIC actions tightening FIA and indexed universal life (IUL) illustration practices over the past decade. The original AG 49 took effect in 2015, AG 49-A in 2020, and the IUL Illustration Subgroup continues to study related issues for life insurance products.
The pattern is consistent: as indexed products grew from a 24% share of the annuity market a decade ago to roughly 45% in 2025, regulators have steadily required more conservative and more transparent disclosures. The April 1, 2026 update fits that pattern.
