CO| Colorado’s Division of Insurance reissued Bulletin B-5.57 on October 26, 2026, outlining its expectations for admitted property and casualty insurers’ use of aerial imagery and imagery-derived data in underwriting and claims decisions, including tools developed internally or supplied by third-party vendors. The bulletin supports aerial imagery as one of multiple assessment tools but emphasizes that it should not be the sole basis for adverse actions, including eligibility determinations, nonrenewals, cancellations, or claim denials or reductions. It expresses the Division’s interpretation and policy rather than independently establishing binding requirements, and excludes specified uses of imagery in catastrophe-loss and wildfire-probability modeling.
- Insurers should assess image quality, resolution, capture date, and other technical limitations; use imagery generally no more than 12 months old for underwriting and sufficiently recent to reflect post-loss conditions for claims; and obtain additional reliable verification before taking adverse action. Decisions should distinguish cosmetic appearance from material deterioration or damage and remain consistent with filed underwriting criteria and guidelines.
- Insurers are directed to provide consumers with aerial images used in adverse actions and should give applicants and policyholders a meaningful opportunity to dispute accuracy, correct errors, submit updated information, and document repairs. Insurers should review those submissions, consider further evaluation or reconsideration, and investigate further when imagery does not clearly establish the cause, extent, or severity of claimed damage.