NAIC Climate Scenario Interrogatory data is now flowing to state regulators for a second consecutive year, and Guy Carpenter’s latest read of the filings shows insurers settling into a routine that will govern one more reporting cycle before regulators decide what comes next. Guy Carpenter’s July 2026 report marks the close of Year 2 of the NAIC’s three-year RBC Climate Interrogatory, which wrapped in early 2026. Carriers exposed to wildfire or hurricane risk are the ones on the hook, and the interrogatory pushes them to gauge how a warming climate reshapes that catastrophe exposure through climate-conditioned modeling runs.
Inside the RBC Blank: What the Interrogatory Actually Asks
On August 2, 2024, the NAIC’s Financial Condition (E) Committee adopted new interrogatories requiring property-casualty insurers to disclose how a changing climate reshapes their hurricane and wildfire catastrophe exposure, embedded in the catastrophe-risk portion of the RBC blank. Filers have two routes to comply. The time-based option has them run a forward-looking RCP4.5 (or an equivalent SSP) climate pathway projected out to 2040 and 2050 horizons. The frequency-based alternative instead applies a flat 10% increase in major-hurricane and wildfire frequency at the 2040 horizon, rising to a 50% increase by 2050. Either way, the scenario has to run through one of a defined set of regulator-recognized catastrophe models — Verisk (formerly AIR), CoreLogic, RMS, KCC, the ARA HurLoss Model or the Florida Public Model.
Insurers disclose Probable Maximum Losses across several return periods for each peril, but only the 1-in-100-year PML actually feeds the R-Cat charge inside the RBC capital formula — the climate-conditioned figures sit alongside it as informational disclosure, not as a capital add-on. That distinction is the one regulators keep underlining, and it is why filers have largely treated the exercise as a modeling and governance project rather than a capital one, leaning on the same catastrophe-modeling infrastructure carriers already run for reinsurance placement, a point documented in Guy Carpenter’s June 1 renewal outcomes for cedents.
Two Filing Cycles Down, One to Go Before 2027
The requirement started with the YE24 RBC filing, due March 1, 2025 — Year 1 of the mandate. Guy Carpenter’s own review places the close of Year 2 in early 2026, when the YE25 filings came due. Under the NAIC’s own timetable, the interrogatories stay in force through the YE26 filing as well, after which regulators will decide whether to extend the three-year requirement or let it lapse. That leaves one more filing cycle before the exercise’s future is settled — a decision that sits with the NAIC’s Climate Resiliency Task Force, the body that oversees the interrogatory framework.
Guy Carpenter, operating under the Marsh umbrella, says its role across the first two interrogatory years has centered on hands-on analytics work, help preparing filings regulators will accept, and climate-science grounding for the underlying scenarios. That advisory workload is compounding on top of an already busy state compliance calendar: insurers working through the climate interrogatory are, in many cases, the same filers tracking the NAIC’s parallel state-by-state push on AI model governance, a second front of regulator-driven disclosure landing on the same compliance desks.
A Disclosure Burden Landing in a Softening Market
The timing is notable because the interrogatory’s third year arrives just as reinsurance capacity is easing pricing rather than adding to it. The global property-catastrophe rate-on-line index fell to -16% at the July 1 renewals, down from -12% in January, according to Guy Carpenter’s report on traditional reinsurance market conditions, an extension of the same easing already visible at the July 1 renewals. Catastrophe bond issuance kept notching fresh highs over the same stretch, pushing outstanding limit past the $61 billion mark. That gives cedents an alternative pool of risk-transfer capacity to weigh against any climate-conditioned PML growth the interrogatory surfaces.
The softening is broad enough that primary carriers are feeling it too, with primary US property rates reported softening into storm season, and it shows up concretely at Florida’s state-backed insurer of last resort, which has repriced its own reinsurance tower even as its book carries exactly the wildfire and hurricane exposure the NAIC interrogatory is built to interrogate. The disclosure regime is also arriving alongside other federal-level moves cedents are tracking, including the House’s action on the federal terrorism-reinsurance backstop, a reminder that climate exposure is only one line item on a widening regulatory agenda for US property risk.
What Insurers, Reinsurers and Regulators Should Take From Year Two
For insurers, the practical takeaway is that climate-conditioned PMLs remain a disclosure and governance exercise rather than a number the R-Cat charge captures directly — but that could change if regulators opt to extend or tighten the requirement once the YE26 filing closes it out. For reinsurers, the interrogatory adds a standardized data layer to underwriting conversations with cedents, even as abundant capacity pushes property-catastrophe pricing in the opposite direction. For state regulators, the coming decision on whether to extend the three-year mandate will test whether an informational-only regime remains adequate once compounding climate scenarios point to materially larger tail losses than today’s baseline models show.
Frequently Asked Questions
Mini-FAQ : APRA Finalises Longevity Capital Rules a
What is the NAIC Climate Scenario Interrogatory?
Does the climate-conditioned PML affect an insurer’s RBC capital charge?
How long will the interrogatory remain mandatory?
Sources Used
- NAIC, climate scenario interrogatory presentation (August 2024)
- Guy Carpenter, Year 2 NAIC Climate Scenario Interrogatory analysis (July 2026)
- NAIC, Climate Resiliency Task Force committee page
- Guy Carpenter, traditional reinsurance market conditions at July 1 renewals
- Guy Carpenter, June 1 reinsurance renewal outcomes for cedents
