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NAIC Climate Risk Disclosure Survey

Intent and Purpose

The Climate Risk Disclosure Survey is a risk management tool for state insurance regulators to request from insurers on an annual basis a non-confidential disclosure of the insurers; assessment and management of their climate-related risks.

The purpose of the Climate Risk Disclosure Survey is to:

Enhance transparency about how insurers manage climate-related risks and opportunities.
Identify good practices and vulnerabilities.
Provide a baseline supervisory tool to assess how climate-related risks may affect the insurance industry.
Promote insurer strategic management and encourage shared learning for continual improvement.
Enable better-informed collaboration and engagement on climate-related issues among regulators and interested parties.
Align with international climate risk disclosure frameworks to reduce redundancy in reporting requirement.

Historical Overview

The Insurer Climate Risk Disclosure Survey, adopted by the NAIC in 2010, was designed to be an insurer reporting mechanism that would provide regulators with a window into how insurers across all lines of insurance assess and manage risks related to climate change. The original eight-question survey asked insurers to provide a description of how they incorporate climate risks into their mitigation, risk management, and investment plans.

All the states were to administer the survey to their domestic insurance companies that write more than $500 million in direct premium. Approximately two dozen states surveyed their companies, and the data was aggregated. In 2011, the threshold was lowered to all companies writing $300 million in premium, however, California was the only state to continue to survey its insurance market. In 2012, California, along with New York and the state of Washington, began administering the Survey to all insurance companies licensed in these states, and that write at least $300 million, making the survey mandatory and the results public. In 2013, the threshold was lowered to $100 million, and the multi-state group was expanded to include Connecticut, Minnesota, and New Mexico.

In 2021, the disclosure survey initiative was joined by nine more states/jurisdictions, reaching 15 members: California, Connecticut, Delaware, District of Columbia, Maine, Maryland, Massachusetts, Minnesota, New Mexico, New York, Oregon, Pennsylvania, Rhode Island, Vermont, and Washington. That year, more than 1,400 companies responded, capturing nearly 80% of the entire U.S. insurance market, allowing regulators, insurance companies and interested members of the public the ability to identify trends, vulnerabilities, and best practices by the insurance industry with respect to climate change.

In April 2022, The NAIC adopted a new standard for insurance companies to report their climate-related risks, in alignment with the international Task Force on Climate-Related Financial Disclosures (TCFD). The TCFD standard is the international benchmark for climate risk disclosure and will help insurance regulators and the public to better understand the climate-related risks to the U.S. insurance market. The NAIC Climate Risk & Resiliency Task Force determined that implementing a TCFD-aligned disclosure framework would enhance transparency about how insurance companies manage climate-related risks and opportunities and incorporate international best practices, among other benefits.

More information about reporting and past survey submissions are maintained on the California Department of Insurance's website and can be accessed below.

Reporting Guidance

The Reporting Year 2023 of the NAIC Climate Risk Disclosure Survey, Notice to Insurers, will be sent in June of 2024. Insurer survey responses are due August 30, 2024. The e-mail notification is sent to the insurance company contact provided on the most recent NAIC Annual Report (Schedule T). The Survey questions will be based on the adopted TCFD-aligned disclosure framework.