CO| Colorado Division of Insurance Bulletin No. B-5.57, issued March 16, 2026, sets forth the Division’s position on the use of aerial imagery by admitted property and casualty insurers in underwriting, pricing, and claims decisions. The Division supports aerial imagery as a useful risk assessment tool but emphasizes it has inherent limitations and should not be treated as definitive or determinative on its own, requiring insurers to exercise reasonable care regarding image quality, timeliness (no more than 12 months old for underwriting), and appropriate resolution for the decision at hand.
Key Points:
- Policyholders must be afforded a meaningful dispute process. Applicants and policyholders impacted by adverse actions supported by aerial imagery must be given the opportunity to dispute the accuracy of the imagery, correct errors, provide updated information, and submit proof of completed repairs or remediation, with insurers required to review such submissions and consider whether reconsideration is warranted.
- Aerial imagery must not be the sole basis for adverse actions. Insurers must distinguish cosmetic conditions from material degradation or functional damage, obtain additional verification (e.g., physical inspections, qualified professional documentation, or updated imagery) before taking adverse actions such as nonrenewals, cancellations, coverage restrictions, or claim denials.