Ceres submitted a comment letter strongly supporting California’s proposal to require the state’s largest insurers to develop and submit comprehensive plans to manage climate-related and other emerging financial risks. The letter frames the proposal as a first-of-its-kind forward-looking solvency planning requirement in the US, citing recent market stress including estimated insured losses of USD 25 billion to USD 40 billion from the January 2025 Los Angeles wildfires, withdrawals or non-renewals by major carriers such as State Farm, Allstate and Farmers, and growth in the California FAIR Plan to 646,000 policies, a 123% increase since 2021. Ceres recommends aligning the new planning requirement with existing Task Force on Climate-related Financial Disclosures reporting cycles, developing implementation guidance for smaller carriers, requiring public disclosure of plans, and updating plans regularly to reflect evolving climate science and best practices.
Ceres 2025-11-14
Ceres urges California to adopt rule requiring large insurers to file long-term climate and emerging risk management plans
Ceres backs California's proposal for major insurers to submit plans for managing climate and financial risks, calling it a pioneering US solvency requirement. The letter cites recent market stress, including $25-40 billion in losses from the January 2025 Los Angeles wildfires and growth in the California FAIR Plan. Ceres suggests aligning with Task Force on Climate-related Financial Disclosures cycles, offering guidance for smaller carriers, mandating public disclosure, and updating plans regularly.