Updated October 1, 2026.
Direct answer: The Reporting Year 2025 NAIC Climate Risk Disclosure Survey deadline passed on August 31, 2026; insurers that write more than $100 million nationwide direct premium in participating states filed TCFD-aligned responses through the California-hosted portal, and those answers are now supervisory data state departments of insurance can act on. The SEC’s March 2024 climate disclosure rules never took effect, remain stayed, and are only in proposed rescission rulemaking as of October 2026—material climate risk under Regulation S-K materiality still applies, and state insurance disclosure did not wait on Washington.
The SEC is still trying to bury the 2024 climate disclosure rule. Your NAIC survey already landed. Federal rescission is a dead rule walking; the state stack collected the file.
If you write US premium in a survey state, the regulator wanted a TCFD-shaped answer for Reporting Year 2025—not an SEC 10-K exhibit. Treaty partners and rating committees never used the federal form as their only input. They used your CAT file and whether the placer can explain the number. That split is sharper now that the August filing window is closed.
What the SEC move actually is
The Commission adopted climate disclosure rules in March 2024. They never took effect: the Eighth Circuit stayed them in April 2024, and the SEC abandoned its defense in March 2025. On May 29, 2026 the Commission formally proposed rescission in full (Release No. 33-11421 / Release 2026-49), calling the 2024 package a dramatic overreach. The comment period closed August 3, 2026, with more than 19,000 comments on the record. As of an August 31, 2026 status report to the Eighth Circuit, rescission rulemaking is still underway and under comment review. A final repeal rule has not been adopted as of October 1, 2026.
What still binds issuers is the older frame: the SEC’s 2010 climate interpretive guidance remains in place, and material climate risk that is already material under Regulation S-K did not go on vacation. Materiality is the North Star—not a blank page, and not the full 2024 rulebook.
We walked the broader NAIC and state landscape here: Insurance regulatory convergence 2026. This piece is the October cut after the filing date.
What happened on August 31
The California Department of Insurance hosts the multi-state NAIC Climate Risk Disclosure Survey. Reporting Year 2025 notices went out in July 2026. Responses were due August 31, 2026. More than two dozen jurisdictions—including California, Illinois, and New York—collected through that portal. Insurers with over $100 million nationwide direct written premium in survey states were required to respond. The questions follow the TCFD-aligned framework the NAIC adopted in 2022.
This is a state supervisory tool, not an SEC form. Proposed federal rescission does not cancel a California-hosted insurer survey that already closed. Filings are becoming public supervisory data; state departments of insurance review them alongside market conduct, financial exams, and climate bulletins—not as a favor to Wall Street rulemaking.
What DOIs do with the file
Expect follow-up questions where governance, investment, or underwriting narratives do not match catastrophe submissions, loss trends, or prior-year answers. The survey is a consistency check across the stack regulators already hold. If the contact on Schedule T left in March, the company still had to file in August; ownership gaps show up in October as supervisory noise.
California SB 253 runs on a different clock
Insurer climate surveys and corporate GHG reporting are not the same program. California’s SB 253 emissions reporting is moving toward its first report, targeted November 10, 2026, on a separate track from the NAIC TCFD survey. Do not merge them in one slide for the board. Federal SEC rescission talk does not pause either state line.
What the treaty desk still wants
Reinsurers price physical risk off the CAT model and the claims story, not off whether Item 1500 still exists on a stayed federal rule. If the placer cannot explain the number, the carrier never sees it—that is the producer seat, not a firm endorsement. Scope 3 and vendor data still show up in claims conversations; we put that on the RCP / carriers piece.
Do not tell the board “climate reporting is over.” Tell them which stack is still live: NAIC survey responses on file, state climate bulletins, rating-agency questionnaires, the treaty submission, and—where applicable—SB 253. The SEC proposal is one stack. It was never the whole desk. For treaty mechanics, see Reinsurance: The Complete Professional Guide (2026) and catastrophe portfolio management.
Physical hazard repricing does not wait on comment review in Washington. Carriers are living that in rate and capacity already—see climate risk and insurance pricing in 2026 and catastrophe model updates.
Bank lessons for the next cycle
- Lock survey ownership in compliance or enterprise risk, not “legal will handle it” after the due date passes.
- Reuse last year’s TCFD narrative only where the facts still hold. Update CAT, reinsurance, and investment sections with Reporting Year 2025 numbers—the ones you just certified.
- Keep one materiality memo for the 10-K: shorter than the 2024 rule, not zero pages, aligned to S-K and 2010 guidance while rescission is pending.
- Reconcile NAIC answers to treaty packs and rating questionnaires now, while exam staff are reading the same PDF you filed.
- Track licensing, reporting, and market conduct calendars separately from SEC comment periods—they do not sync.
Federal climate disclosure is a form fight stuck in rulemaking. The survey was a date and a number—and for Reporting Year 2025, that date is behind you.
Sources: SEC Release 2026-49 / 33-11421 (29 May 2026 proposed rescission; comment period closed 3 August 2026); CDI / NAIC Climate Risk Disclosure Survey (Reporting Year 2025 due 31 August 2026).
Frequently asked questions
Did the August 31, 2026 NAIC Climate Risk Disclosure Survey deadline get cancelled?
No. The Reporting Year 2025 deadline was August 31, 2026. Proposed SEC rescission of the 2024 corporate climate rules did not cancel the NAIC insurer survey or the state portals that collected it.
Is the SEC climate disclosure rule gone as of October 2026?
Not by final action. The March 2024 rules never took effect and remain stayed. The SEC proposed full rescission on May 29, 2026; comments closed August 3, 2026; and rescission rulemaking was still underway as of late August 2026. A final repeal had not been adopted as of October 1, 2026.
Does federal rescission mean insurers can ignore state climate disclosure?
No. The NAIC TCFD-aligned survey is a state supervisory program hosted through California’s portal, with more than two dozen participating jurisdictions. It operated on its own calendar and already collected Reporting Year 2025 responses.
What happens to NAIC survey responses after filing?
They become insurer-specific supervisory data for participating departments of insurance. Regulators use them to assess governance, strategy, risk management, and metrics—often cross-checked against financial filings, catastrophe modeling, and market conduct.
What should carriers do now that the August 2026 survey is filed?
Reconcile survey narratives to treaty submissions and rating questionnaires, refresh CAT and reinsurance sections for the next cycle, maintain a materiality-based SEC narrative under Regulation S-K, and track California SB 253 and other state GHG programs on their own deadlines.
How is the NAIC survey different from California SB 253?
The NAIC survey is a TCFD-aligned insurer climate risk disclosure collected through state insurance regulation. SB 253 is a separate California greenhouse gas emissions reporting regime for covered entities, with its first report targeted November 10, 2026—not a substitute for or duplicate of the NAIC filing.