The National Association of Insurance Commissioners (NAIC) has published an analysis estimating U.S. insurers’ private credit holdings at USD 1.21 trillion at the end of 2025, approximately 13% of cash and invested assets. Within that total, USD 544 billion comprised privately rated bonds, business development companies and private credit funds identified as primary areas of focus because they may introduce additional risks through structural complexity or exposure to alternative assets. These holdings represented approximately 6% of cash and invested assets and 9% of total bond holdings. More than half of the broader private credit total consisted of private placement bonds, bank loans and middle-market collateralized loan obligations, generally involving more straightforward credit risks and structures that regulators have long monitored. Within the focus categories, privately rated bonds accounted for USD 512 billion, with business development companies and private credit funds accounting for USD 32 billion. Limited transparency can complicate assessments of credit quality, valuation and liquidity. The performance of more complex private credit investments under a severe economic and market downturn remains uncertain. The exposure figures are estimates based on existing reporting requirements and available data, with identifiable overlaps between categories removed. Enhanced disclosures adopted in 2026 will be included in insurers’ year-end 2026 annual statement filings. These will distinguish among types of private placement securities and are expected to improve the identification and classification of private credit exposures.

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