SEC Scraps Climate Disclosure as P&C Reporting Fragments Across State, Federal, and EU Regimes

The Securities and Exchange Commission voted on May 29, 2026 to propose full rescission of its 2024 climate-related disclosure rules, calling them "unsound as a matter of policy" and a "dramatic overreach" of statutory authority. The proposal, published June 3, estimates annualized savings of roughly $4.9 billion a year over ten years across all registrants. For P&C carriers it removes the unified federal framework, not the obligation.

Key Takeaways

• The 2010 Interpretive Release becomes the sole federal framework again: materiality-based climate disclosure under Regulation S-K and S-X, with no emissions reporting requirement, no standardised format and no attestation.
• Five return periods of climate-conditioned probable maximum loss, at 1-in-50 through 1-in-1,000, are what the NAIC's RBC interrogatories still require from P&C insurers for hurricane and wildfire, through year-end 2026 filings.
• Three permitted methodologies for those interrogatories, from a flat 10% and 50% frequency uplift to vendor catalogues calibrated to RCP 4.5 for 2040 and 2050, mean two carriers can comply and produce numbers that are not comparable.
• 29% of insurers disclosed metrics and targets in the NAIC climate survey against 99% reporting on risk management processes, virtually unchanged year over year.

What Was Removed and What Was Never in Force

The rules were adopted March 6, 2024 on a 3-2 vote, requiring Scope 1 and Scope 2 emissions, climate risk management practices, scenario analysis and internal carbon pricing, transition plans, climate-related financial statement effects, and third-party attestation for large accelerated filers on a phased basis, with compliance from fiscal 2027.

They never took effect. Petitions across six circuits consolidated before the Eighth Circuit, the SEC stayed implementation on April 4, 2024, voted to end its defence on March 27, 2025, and told the court on May 7, 2026 that it would propose rescission. Comments close August 3, 2026.

What the rescission actually costs P&C carriers is the financial statement effects provision. It would have required disclosure of how climate risk moved specific balance sheet, income statement and cash flow line items, which for a homeowners or commercial property writer in catastrophe-exposed territory means quantifying how loss patterns and reinsurance cost changes reach the accounts. That is the one part of the rule with no state or international substitute.

Chairman Paul S. Atkins framed the retreat institutionally: "We need to stick to our knitting. Let the Environmental Protection Agency do their job and we stick to our job."

The asymmetry falls on the carriers that prepared. Chubb, Travelers and AIG had built climate governance and reporting infrastructure toward a level approaching what the rule required. They keep the capability and lose the level-setting that would have obliged peers to match it.

The Surviving Mandate Is the Technical One

Framework	Scope	Content	Next Deadline
SEC 2010 Guidance	All public registrants	Material climate risks under Reg S-K/S-X	Each 10-K filing
CA SB 253	>$1B revenue, doing business in CA (insurer exemption pending)	Scope 1 & 2 GHG emissions	August 10, 2026
CA SB 261	>$500M revenue (insurer exemption; currently enjoined)	TCFD-aligned financial risk report	TBD (injunction pending)
NAIC Survey	≥$100M DWP in 15 participating states	TCFD four-pillar disclosure	August 31, 2026
NAIC RBC Interrogatories	P&C insurers (YE24-YE26)	Climate-conditioned cat exposure (hurricane, wildfire)	March 1, 2027 (YE26 filing)
EU CSRD	>1,000 employees + €450M turnover	ESRS sustainability standards	FY 2027 (reports due 2028)

Nothing in that list replaces the SEC rule, and the frameworks do not reconcile: different scoping thresholds, timelines and assurance requirements. California's two laws exempt insurers directly, SB 261 by express exclusion of entities regulated by the Department of Insurance and SB 253 by a proposed extension of the same, though SB 253 will still generate Scope 1 and 2 emissions data from thousands of California-operating companies, which reaches carriers as policyholder data rather than as a filing obligation.

The framework that actually asks P&C actuaries for numbers is the NAIC's RBC climate scenario interrogatories, adopted August 2, 2024 and running from year-end 2024 through year-end 2026. They require climate-conditioned probable maximum losses at five return periods, 1-in-50 through 1-in-1,000, for major hurricanes at Category 3 and above on wind losses only, and for wildfire.

The methodology options are where comparability goes. A carrier may apply a flat 10% and 50% frequency increase to existing catastrophe model output, develop its own time-based view projecting to 2040 and 2050, or use vendor climate-conditioned catalogues calibrated to RCP 4.5 for the same horizons. The first is a sensitivity test on a present-day model. The third is a different hazard model. They are not estimates of the same quantity, and both satisfy the interrogatory.

The interrogatories are informational, reported confidentially, and the NAIC has been explicit that the data will not generate RBC charges. So the one surviving requirement that produces quantified catastrophe exposure produces it in three incompatible forms, behind confidentiality, into a framework that attaches no capital consequence to the answer.

The Frameworks That Remain Collect Narrative

The NAIC's Climate Risk Disclosure Survey is the closest thing the U.S. insurance sector has to a unified standard, TCFD-aligned since its April 2022 overhaul and covering insurers with at least $100 million of direct written premium. The Ceres 2025 progress report read 526 insurance groups representing more than 1,723 companies, and the shape of the responses is the finding.

Across the four TCFD pillars, 99% reported on risk management processes, 97% on strategy and 87% on governance. 29% disclosed metrics and targets, essentially unchanged from prior years. Of the 45 groups that disclosed across all four pillars, none provided the emissions targets needed to track progress against their own commitments, while 87% had established comprehensive climate targets.

That is not a reporting gap. It is a measurement gap: the sector can describe its climate governance in detail and cannot express it as a number. The scenario analysis figures say the same thing from the other side. Use rose 28% year over year to 148 groups, and Ceres found insurers are not applying it to measure portfolio exposure or track financial effects. The tools are bought and not pointed at the balance sheet.

The collecting base is shrinking underneath that. Fifteen states and territories now participate, down from 27, several having withdrawn amid anti-ESG pressure, and the $100 million threshold excludes smaller regional carriers, which in wildfire and coastal markets are frequently the ones with the most concentrated exposure.

So the post-rescission position is not less disclosure than before. It is disclosure that runs on narrative in the survey, on three incompatible methodologies in the confidential interrogatories, and on management discretion in the 10-K, assembled from frameworks with different thresholds and no common denominator, at the point where the underlying peril is the one thing all of them agree is getting harder to price.