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 current iteration of the Survey is aligned with the international Task Force on Climate-Related Financial Disclosures (TCFD).
More information about reporting, past survey submissions, and analysis reports are maintained on the California Department of Insurance's website and can be accessed below.
Please e-mail ClimateRiskSurvey with questions or for technical assistance.
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.
Reporting Guidance
The Reporting Year 2024 of the NAIC Climate Risk Disclosure Survey, Notice to Insurers, will be sent in June of 2025. Insurer survey responses are due August 29, 2025. The e-mail notification is sent to the insurance company contact provided on the most recent NAIC Annual Report (Schedule T). The Survey questions are based on the adopted TCFD-aligned disclosure framework.
A series of capacity building webinars on the TCFD-aligned Survey is archived at the NAIC Climate Risk and Resiliency Resource Center. Recordings are under Public Meetings of the Climate Risk Disclosure tab.
Submissions
To view past climate risk disclosure survey submissions, please click on the relevant reporting year database links below:
- Reporting Year 2011-Current Surveys submitted to AZ, CA, CO, CT, D.C., DE, HI, IL, MA, MD, ME, MI, MN, NH, NM, NV, NY, OR, PA, PR, RI, VT, WA and WI
- Reporting Year 2010 Surveys submitted to CA
- Reporting Year 2009 Surveys submitted to CA
Additional Information and Reports
- An online dashboard of the key RY 2022 individual company survey data as well as comparisons to RY 2021 data (companion to the Ceres 2024 report). Here is a video outlining how to utilize the dashboard
- Ceres 2024 Report: Navigating Climate Risks: Progress and Challenges in U.S. Insurance Sector Disclosures (RY 2022 data)
- Ceres and CDI 2023 Report: Climate Risk Management in the U.S. Insurance Sector (RY 2021 data)
- The Society of Actuaries and the Center for Insurance Policy and Research 2023 Report: Analysis of U.S. Insurance Industry Climate Risk Financial Disclosures for Reporting Year 2021
- The Center for Insurance Policy and Research 2020 Report: Assessment of and Insights from NAIC Climate Risk Disclosure Data (RY 2018 data)
- Ceres Report: Insurer Climate Risk Disclosure Survey Report; Scorecard 2016 Findings and Recommendations (RY 2014 data)
- NAIC Updates: Climate Risk and Resiliency
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.