NAIC Climate and Resiliency Task Force Adopts Revised Climate Risk Disclosure Requirements

24 March 2022
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Key takeaways:
  • On March 21, 2022, the National Association of Insurance Commissioners (“NAIC”) Climate and Resiliency (EX) Task Force adopted a new form of the NAIC Climate Risk Disclosure Survey (“Survey”) to closely align with recommendations by the Task Force on Climate-Related Financial Disclosures.
  • If adopted at the next National Meeting in April 2022, the revised Survey would replace the existing eight-question format that has been administered annually since 2010 by several states.
  • The heightening of ESG-related disclosure requirements by the NAIC is consistent with recent moves by other regulators in the financial regulation space but may give rise to governance concerns and additional expense for insurers.