The U.S. Department of Labor’s (DOL) fiduciary rule—officially the Retirement Security Rule—continues to evolve in ways that matter for insurance carriers and their distribution partners. Designed to expand fiduciary obligations for retirement advice, the rule sought to extend the Employment Retirement Income Security Act’s (ERISA) best-interest standard to a wider range of scenarios, including one-time rollover recommendations.
But a July 2025 court ruling has scaled back the DOL’s guidance while still leaving portions of the fiduciary rule on hold with the potential for future implementation. For carriers, understanding the current state of the rule is key to making informed decisions about oversight, training, and long-term compliance strategy.
What the court decided
On July 8, 2025, the Northern District of Texas issued a mixed decision in Federation of Americans for Consumer Choice v. Department of Labor. U.S. District Judge Ed Kinkeade ruled that a single rollover recommendation does not create fiduciary status under ERISA, striking down the part of the fiduciary rule that treated such advice as an ongoing advisory relationship. This was a central point of contention in the DOL’s expanded interpretation, and the decision effectively limits the rule’s reach when it comes to transactional rollover advice.
While a win for the plaintiffs—comprised of independent agents, financial planners, and industry organizations—Kinkeade’s ruling did not eliminate fiduciary duties more broadly: Advisors who maintain ongoing, individualized relationships with retirement investors remain subject to ERISA’s fiduciary standard. Agents who only sell products to their clients do not have this relationship, the court concluded.
Adding complexity to this decision, the Supreme Court’s June 2025 ruling on nationwide injunctions left existing stays against the fiduciary rule intact, effectively freezing enforcement while appeals move forward. Seeking further rollbacks of DOL’s guidance, plaintiffs have already indicated their intent to appeal the decision.
What the court’s decision means for now
For carriers, the immediate takeaway is that an agent’s recommendation to roll over retirement assets into annuities or individual retirement accounts (IRAs) does not automatically trigger the Fiduciary Rule’s heightened obligations if the advice is isolated and not part of a broader advisory relationship.
Advisors engaged in ongoing, individualized retirement planning continue to fall under fiduciary requirements, and state-level annuity best-interest standards apply in all 50 states as of April 2025, regardless of whether ERISA fiduciary status is triggered.
What’s next: Appeals and other steps
The DOL has been given 60 days to respond to the Texas rulings, and an appeal to the Fifth Circuit Court of Appeals is expected later this summer. Depending on how the appellate court rules or whether the DOL under new administration revises its guidance, the scope of the fiduciary rule could shift again before the end of the year.
In the meantime, carriers should continue to monitor developments closely to ensure that their policies are aligned with current regulatory requirements, even as the extent of those requirements continues to be whittled down in court.
The bigger focus for carriers
Despite this ruling, regulatory scrutiny of retirement advice isn’t going away. Whether through the DOL, the SEC, or state insurance departments, expectations for transparency and best-interest conduct are becoming standard across the industry.
Carriers that maintain consistent oversight and clear guidance for their distribution partners will be better prepared to adapt when courts issue decisions that impact how the industry must operate. Having the right technology platform in place to respond quickly and effectively to changing regulation doesn’t hurt, either.
