Texas Eliminates "Zero Report" Filing Requirement for Surplus Lines
WebCE Staff
By
March 11, 2026
For the 2026 tax filing season (covering the 2025 tax year), the Texas Comptroller's Office has implemented a significant procedural change for the surplus lines industry: Licensed Surplus Lines Agents and Agencies are no longer required to file a "Zero Report" if they have no taxable premium.
This is a departure from longstanding practice, under which any agent or agency holding a surplus lines license for any portion of the year was required to file a return, even if no business was written. The change has been implemented by the Comptroller's Office, as detailed in industry compliance bulletins.
Who Is Affected (And Who Isn't)
This change applies exclusively to Licensed Surplus Lines Agents and Licensed Surplus Lines Agencies in Texas.
This change does not apply to Surplus Lines Insurers, who must continue to file a tax return annually regardless of premium volume. It also does not apply to surplus lines filings in other states; verify zero-report requirements with the Department of Insurance or Stamping Office in jurisdictions outside of Texas.
How the New System Works
The Comptroller's Office has completed programming updates to the Webfile system so that it no longer requires zero reports from surplus lines agents and agencies.
If a licensed agent or agency has zero taxable premium for the reporting period, the system will automatically close the filing period in early April. Agents do not need to log in to Webfile to prove they had no activity. Agents who prefer to file voluntarily may still submit a zero report during March.
Operational Impact & Legacy Issues
This update eliminates the root cause of several recurring friction points going forward.
Previously, agents who did not file a zero report (even when no tax was owed) could receive an Estimated Assessment as though they had failed to comply. Mailing discrepancies compounded the problem, since notices were often sent to an address given by the employer, which could differ from the agent's own. It could even arrive at the wrong place entirely if the agent had moved or was not actively writing surplus lines business. For agents holding a license purely for educational or credentialing purposes, these notices were particularly jarring.
"I have received bills that exceed $7,500 in estimated taxes," said Tabitha Richardson, director of product and market development for financial services at WebCE. "While for the most part I am quite diligent in getting these filled, I have missed the filing deadline and had to negotiate with the Comptroller’s office to eradicate the erroneous invoice."
Critical Exception
This change applies to the 2025 tax year (due March 2, 2026) and forward. If you already have an outstanding Estimated Assessment, a past-due notice, or a delinquency from a prior period, you may still need to file to clear it. "Do nothing" applies only to the current tax year if no tax is due; it does not resolve existing account issues.
Contact the Comptroller's Insurance Tax division at Insurance.Tax@cpa.texas.gov if you have an open balance.
A Note on Late Filing
Because the system auto-closes zero-premium accounts in early April, the filing link for the 2025 tax year will disappear from your Webfile dashboard. Agents attempting to file after the auto-close date will find the reporting period locked. If you miss the window and need to file a return after the system closes (e.g., to correct an audit finding), you must contact the Comptroller's Office directly to have the period manually reopened; Webfile will not allow self-correction after the auto-close date.
Action Plan for the 2026 Filing Season
To ensure compliance for the current season, verify your status below:
If you wrote taxable business in 2025: You must file your Annual Insurance Tax Report and remit payment by March 2, 2026 via Webfile.
Note: The statutory deadline is March 1, but because that date falls on a Sunday in 2026, the deadline extends to the next business day. Do not rely on the standard federal April 15 timeline.
If you wrote $0 taxable business in 2025: No action is required. Per the Comptroller's FAQ, you do not need to file a tax report if you did not place business with your surplus lines license. The filing period will automatically close in April.
Filing Tip: When submitting via Webfile, you will need two specific identifiers:
Taxpayer Number: Your 11-digit Comptroller-assigned number (not your TDI license number).
Webfile Number: A 6-character code starting with RT or XT and typically found in the top right corner of Comptroller correspondence.
If these numbers are unavailable, use the "Problem finding your account?" tool on the Webfile login page or contact the Comptroller's Office before the March 2 deadline.