FOR IMMEDIATE RELEASE: November 14, 2025
CONTACT: Jarice Thompson, Americans for Financial Reform Education Fund, jarice@ourfinancialsecurity.org
Patrick Davis, Public Citizen, pdavis@citizen.org
Washington, D.C. — The insurance industry’s ongoing failure to adequately manage and mitigate climate-related risks requires clear and precise requirements from the California Department of Insurance (CDI) according to new comments from Public Citizen and Americans for Financial Reform Education Fund.
In the comment, which was sent in response to the CDI’s Long-Term Solvency Planning Proposal, the groups highlight the need for insurers to comprehensively address both physical and transition risks across underwriting, investing, and operations.
“Addressing the long-term impacts of climate change is an essential part of risk management for insurers, said Elyse Schupak, policy advocate with Public Citizen’s Climate Program. “Through this proposal, the CDI should require insurers to mitigate risks not just for themselves, but also for the communities they serve. This requires aligning underwriting and investing with science-based emissions reduction targets and working with customers and communities to adapt to the impacts of climate change, rather than retreating from them. While this proposal is a step in the right direction, at present it is more ambiguity than ambition. The Department must strengthen the proposal such that it spurs meaningful risk reduction, rather than greenwashing from insurers.”
Among the recommendations in the comments, the groups call on CDI to require insurers to set physical and transition risk reduction targets, create and implement transition plans consistent with leading frameworks, and disclose their long-term plans to continue offering coverage and paying claims in the geographies and for the customers they currently serve.
“Insurers need to develop climate plans that encompass both climate mitigation and climate adaptation and resilience for themselves and their customers, rather than continuing to invest and insure fossil fuel expansion and then retreat from communities as climate costs grow,” said Alex Martin, climate finance policy director at Americans for Financial Reform Education Fund. “Without action from insurance regulators, climate catastrophes will continue to devastate communities while insurers privatize profits and push climate costs onto the public.”
The comments from Public Citizen and Americans for Financial Reform Education Fund were submitted in response to an initial round of informal feedback that the CDI collected through November 14, 2026. Next, CDI will review the comments and potentially move forward with a formal proposed rule for large insurance companies operating in the state.
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