After several years of declining directors and officers liability insurance prices, brokers may be entering a narrower window to use remaining market competition to improve clients’ coverage before underwriting discipline strengthens.
Howden said D&O rates fell by an average of 6.8% in 2025, following declines of 3.5% in 2024 and 5.1% in 2023. However, more policies renewed without a premium change during the final two quarters of last year, indicating that the pace of reductions was beginning to level off.
“We will be brave and say it again: the market is showing signs of bottoming out,” Howden said.
Independent market data point in a similar direction, particularly in the US. Aon reported that the average price per $1 million of public company D&O limits increased 0.8% year over year in the fourth quarter of 2025, the first quarterly increase since the first quarter of 2022. Among primary policies renewing with the same limit and deductible, 43% received a decrease, 38% renewed flat and 19% saw an increase.
Marsh separaely reported a 1% increase in US D&O rates during the fourth quarter, saying insurers were resisting the large reductions recorded over the previous three years. Some carriers withdrew capacity where they considered pricing inadequate, while many renewals were flat.
WTW has forecast a similar environment for 2026, predicting public company D&O pricing ranging from a 3% decrease to flat and private company pricing from a 5% decrease to flat. It said reductions could remain available for individual risks but expected flat outcomes to become increasingly common for stable accounts.
For brokers, the shift changes the commercial opportunity at renewal. Rather than assuming another round of substantial premium savings, clients may have an opportunity to use remaining competition among insurers to negotiate broader coverage, higher sublimits or other improvements before underwriting discipline strengthens further. In practice, that could mean pushing to broaden the definition of a covered claim to capture regulatory investigations and formal demands, not just filed lawsuits, or increasing Side A difference-in-conditions limits that protect individual directors when the company itself cannot indemnify them - both areas where insurers still have room to concede given current market conditions.
That consideration may be particularly relevant because many insureds have so far retained their savings rather than increasing protection. Howden said the proportion of its insureds changing their D&O limits fell from 13% in 2024 to 11.5% in 2025. At the same time, excess-layer competition remained particularly strong, with rates for non-US listed insureds falling by more than 20% for three consecutive quarters.
WTW has similarly said buyers may be able to seek value through coverage enhancements or increased sublimits as insurers have less room to cut pricing.
That comes as the claims picture becomes more complex, even though US securities litigation has not broadly increased. NERA recorded 207 new federal securities class actions in 2025, down 11% from 232 in 2024. AI-related filings nevertheless rose to 17, while crypto-related cases increased to 14 from eight.
Settlement trends were mixed. Aggregate securities class action settlements fell 25% on an inflation-adjusted basis to $2.9 billion, but the median settlement rose 21% to $17 million, the highest level in a decade.
Howden also highlighted derivative litigation, noting that 243 of 512 securities class action settlements between 2019 and 2024 involved parallel derivative actions. AI is another emerging area, with potential exposures extending beyond alleged misrepresentation to board oversight, disclosure and capital allocation.
Private credit is also being monitored as a potential source of insolvency-related D&O claims, although Howden stopped short of calling it a systemic threat.
Regulatory developments are adding to exposures. The UK's Economic Crime and Corporate Transparency Act introduced a corporate failure-to-prevent-fraud offense from Sept. 1, 2025. Howden said related scrutiny could create D&O exposures for individuals responsible for fraud prevention, although corporate criminal fines would not be covered.
Pricing also varies by region. In Asia, Howden said the market remains favorable to buyers, particularly for excess layers, even as reductions ease and some programs renew flat. Marsh reported fourth-quarter financial and professional lines rates falling 10% in the region, with D&O pricing declining across most Asian markets.
For brokers, the divergence makes renewal strategy more important. With US pricing stabilizing while liability exposures continue to evolve, the opportunity may increasingly be to use remaining buyer leverage to strengthen limits, wording and program structure rather than focus solely on further premium reductions.
