# NAIC Climate Risk Disclosure Survey: 29-Jurisdiction TCFD Mandate for Insurers (> $100M DWP)

> Canonical URL: https://bcesg.org/naic-climate-risk-disclosure-survey-tcfd-insurer-mandate-guide/
> Jurisdiction: Multi-State Coalition (23 States + D.C. + 5 U.S. Territories) | Status: LIVE SECTORAL MANDATE — Licensed Insurers >= $100M Countrywide DWP | Reviewed: 2026-11-14

**Short answer:** While cross-sector state climate laws remain limited outside California, the U.S. insurance industry already operates under a nationwide mandatory climate-risk reporting regime. Administered jointly by the [California Department of Insurance (CDI RY2025 Notice, July 7, 2026)](https://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/ClimateSurvey/upload/Climate-Risk-Disclosure-Survey-Notice-RY-2025.pdf) and partner regulators across **23 states, Washington, D.C., and 5 U.S. territories**, the Task Force on Climate-Related Financial Disclosures (**TCFD**)-aligned NAIC Survey captured more than 1,800 companies representing **over 86% of the U.S. insurance market**.

Unlike California SB 261—from which insurers are expressly exempt—the NAIC Survey has remained continuously active and un-enjoined. Crucially for compliance teams at multi-line carriers (>$1B revenue), neither the NAIC Survey nor SB 261's insurer exemption waives [California SB 253](https://bcesg.org/california-sb-253-sb-261-compliance-playbook/) GHG Scope 1 and 2 emissions obligations for major carriers doing business in California.

### Statutory Status at a Glance
- **Governing Coalition (29 Jurisdictions):** CA (host) + CO, CT, DE, DC, HI, IL, ME, MD, MA, MI, MN, NV, NH, NJ, NM, NY, OR, PA, RI, VT, VA, WA, WI + AS, GU, MP, PR, VI.
- **Mandatory Premium Floor:** **>$100 million** in countrywide Direct Written Premiums (DWP) if licensed in any participating jurisdiction.
- **Required Content Architecture:** TCFD 4-pillar narrative (Governance, Strategy, Risk Management, Metrics & Targets) submitted via [CDI's portal](https://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/ci/index.cfm) or partner commissioner portal, plus voluntary closed-ended NAIC questions.
- **Per-Entity Group Rule:** Uniform group policy narratives are allowed across affiliates, but CDI strictly requires an individual submission document per licensed legal entity >$100M DWP.
- **New York & California Intersections:** NY carriers also adhere to NY DFS [11 NYCRR 82](https://www.dfs.ny.gov/industry_guidance/climate_change) climate governance; CA SB 261 exempts insurers, whereas CA SB 253 (>$1B) does NOT.

## Who Must File, Reciprocal Portal Routing, and Per-Entity Group Rules

Under CDI's Reporting Year 2025 notice (covering calendar 2025 direct written premiums for the August 2026 call), jurisdiction attaches through state **licensure** combined with **countrywide** premium volume >$100 million — not in-state premium volume alone. A mid-sized carrier with $120M nationwide DWP and just $5M of business in Oregon or Pennsylvania is fully in scope.

To prevent duplicate reporting across the 29 participating regulators, CDI allows carriers required to file in another participating partner state or jurisdiction to submit there rather than filing twice. However, CDI specifically audits multi-entity insurance holding companies: even when group-wide policies match identically across subsidiaries, each legal entity individually exceeding $100M DWP must have a corresponding filing tied to its NAIC company code.

- **Public Record Publication:** All participating survey narratives and prior-year responses publish openly on CDI's Climate Risk Disclosure database, creating public comparability across underwriting, investment portfolio carbon risk, and physical catastrophe pricing.
- **Closed-Ended Supplemental Questions:** Alongside the narrative TCFD document, CDI requests responses to aligned closed-ended Y/N SurveyMonkey benchmarking items supporting NAIC industry aggregation.

| Coalition / Dimension | Scope & Participating Jurisdictions | Key Rule / Threshold |
| --- | --- | --- |
| Partner States (23) | CA, CO, CT, DE, HI, IL, ME, MD, MA, MI, MN, NV, NH, NJ, NM, NY, OR, PA, RI, VT, VA, WA, WI | Licensed insurer >$100M countrywide DWP triggers annual filing |
| District & Territories (6) | District of Columbia + American Samoa, Guam, N. Mariana Is., Puerto Rico, USVI | Partner filing reciprocity avoids double submission |
| CA SB 261 vs. SB 253 | CA H&SC §§ 38533 (SB 261) & 38532 (SB 253) | EXEMPT from SB 261; NOT exempt from SB 253 if >$1B revenue |
| New York DFS Layer | 11 NYCRR 82 / NY Insurance Circular Letter No. 15 | Board governance & enterprise risk integration alongside NAIC |

![Compliance overview of the NAIC Climate Risk Disclosure Survey across 23 states, D.C., and 5 territories for insurers >$100M direct written premium, showing TCFD pillars and CA SB 261 exemption.](https://bcesg.org/wp-content/uploads/2026/11/infographic-naic-tcfd.png)

## Why State Insurance Regulation Intersects with Cross-Sector Disclosure Laws

Even in states listed as 'None Found' for cross-sector corporate disclosure statutes—such as [New York](https://bcesg.org/new-york-climate-corporate-data-accountability-act-s9072a-a4282a-watch/), [New Jersey](https://bcesg.org/new-jersey-climate-corporate-data-accountability-act-s679-watch/), and [Illinois](https://bcesg.org/illinois-climate-corporate-accountability-act-hb-3673-watch/)—the NAIC TCFD Survey binds major carriers every single year.

At the same time, California Health & Safety Code § 38533 expressly carved insurers out of SB 261 precisely to defer to the NAIC/CDI framework—making the NAIC TCFD submission the de facto national insurer financial-risk standard while SB 261 sits in Ninth Circuit litigation.

## Compliance Execution Checklist

| Step | Owner / Team | Auditable Deliverable |
| --- | --- | --- |
| 1. Legal-Entity DWP Screen | Regulatory / Actuarial | Flag every licensed insurance affiliate exceeding $100M countrywide DWP for the reporting year. |
| 2. Home-State Reciprocity Check | Compliance Lead | Confirm whether domiciliary partner state (e.g., NY, PA, IL) collects directly vs. California CDI portal. |
| 3. 4-Pillar TCFD Narrative | ERM / Chief Investment | Update Governance, Strategy, Risk Mgmt & Metrics/Targets plus closed-ended NAIC Y/N supplement. |
| 4. Separate CA SB 253 Gate | ESG Reporting | If insurer group entities >$1B rev do business in CA, maintain Scope 1 & 2 GHG filings + Dec 10 fee track. |

## Frequently Asked Questions

### How many states enforce the NAIC TCFD Climate Risk Disclosure Survey?

As of the July 7, 2026 Reporting Year 2025 Notice, California plus 22 partner states (23 states total), the District of Columbia, and 5 U.S. territories (29 U.S. jurisdictions) enforce the TCFD-aligned NAIC Survey.

### Can an insurance holding company file one group PDF for all subsidiaries?

Uniform group narratives are allowed when affiliate policies and practices match, but CDI requires an individual filing document submitted for each licensed legal entity exceeding $100 million in countrywide DWP.

### Are insurers exempt from California SB 253 as well as SB 261?

No. Health & Safety Code § 38533 exempts insurance companies from SB 261 (financial risk reporting), but H&SC § 38532 (SB 253 Scope 1/2/3 GHG emissions for >$1B entities) contains no insurer exemption.

## Primary Authorities & Official Resources

- [California Dept. of Insurance — RY2025 Climate Risk Disclosure Survey Notice (PDF)](https://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/ClimateSurvey/upload/Climate-Risk-Disclosure-Survey-Notice-RY-2025.pdf)
- [California Dept. of Insurance — Climate Risk & Resiliency Initiatives Portal](https://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/ci/index.cfm)
- [NY Dept. of Financial Services — Climate Change & 11 NYCRR 82](https://www.dfs.ny.gov/industry_guidance/climate_change)
- [BC ESG — California SB 253, SB 261 & AB 1305 Playbook](https://bcesg.org/california-sb-253-sb-261-compliance-playbook/)

*Informational notice: This guide summarizes enacted statutes, regulations, or pending legislative records from the primary authorities linked above as of November 14, 2026. It is not legal, accounting, or licensed engineering advice.*