The SEC is trying to bury the 2024 climate disclosure rule. Your August 31 NAIC Climate Risk Disclosure Survey did not get the memo.
If you write US premium in a survey state, the regulator still wants a TCFD-shaped answer this month. Treaty partners and rating committees never used the SEC form as their only input. They used your CAT file and whether the placer can explain the number.
What the SEC move actually is
On 29 May 2026 the Commission proposed to rescind the March 2024 climate rules in full (Release 2026-49). The rules have been stayed since April 2024. Comments closed in early August. A final repeal, if it comes, is late 2026 or 2027. Material climate risk that is already material under Regulation S-K did not go on vacation. Atkins called materiality the North Star. That is the old test, not a blank page.
We already walked the broader NAIC landscape here: Insurance regulatory convergence 2026. This is the filing-week cut.
What is due on 31 August
The California Department of Insurance, which hosts the multi-state NAIC Climate Risk Disclosure Survey, says Reporting Year 2025 notices went out in July 2026. Responses are due 31 August 2026. The questions follow the TCFD-aligned framework the NAIC adopted in 2022. The contact on Schedule T gets the email. If that person left in March, the survey is still due.
This is a state supervisory tool, not an SEC form. Two dozen jurisdictions collect through that portal. Killing a federal 10-K climate section does not cancel a California-hosted insurer survey.
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. If the placer cannot explain the number, the carrier never sees it — that is the producer seat at USI, 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, state climate bulletins, rating-agency questionnaires, and the treaty submission. The SEC proposal is one stack. It was never the whole desk.
This week
- Find who owns the 31 August NAIC survey. If the answer is “legal will handle it,” you are already late.
- Reuse last year’s TCFD narrative only where the facts still hold. Update CAT, reinsurance, and investment sections with 2025 numbers.
- Keep one materiality memo for the 10-K in case S-K still requires a climate risk factor. That memo is shorter than the 2024 rule. It is not zero pages.
- Do not stall a treaty pack waiting for Washington. The model run does not care about Release 2026-49.
Federal climate disclosure is a form fight. The survey and the treaty are still a date and a number.
Sources: SEC Release 2026-49 (29 May 2026); CDI / NAIC Climate Risk Disclosure Survey (RY 2025 due 31 August 2026).