Aerial Imagery Used by Homeowners Insurers

Department of Business Regulation Insurance Division 1511 Pontiac Avenue, Bldg. 69-2 Cranston, Rhode Island 02920 Insurance Bulletin Number 2025-3 Aerial Imagery Used by Homeowners Insurers The Department is issuing this bulletin to address the use of aerial imagery, including satellite imagery, in the underwriting of homeowners insurance policies and the settlement of claims. This Bulletin is intended to apply to the initial consideration of risks, the tiering of risks, and the non-renewal of policies using aerial imagery as well as the determination of causes and amounts of loss. The Department is aware that some insurers are non-renewing or refusing to write Rhode Island homeowners insurance policies based on property characteristics identified through aerial imaging. While the Department does not seek to restrict an insurer’s ability to utilize aerial imagery as a part of their underwriting toolkit, it must be used responsibly. Images used to evaluate a property risk must provide a clear, accurate, and current (less than 15 months old) view of the property. Images of insured property that are low-resolution, out-of-focus, blurry, or not current do not provide an accurate and clear representation of the property, and thus cannot alone justify a cancellation or nonrenewal based on the condition of the property without further investigation into the condition of the property. Additionally, aerial images of a roof that show only cosmetic damage such as streaking or discoloration without functional or structural damage are not sufficient to independently support cancellation or nonrenewal based on roof degradation, as cosmetic damage alone is not reason to justify these actions. To justify underwriting action, there must be clear evidence of significant material degradation or damage that increases the risk of loss. If inconclusive aerial imagery creates concerns, an insurer should obtain recent, clear information through a physical inspection or otherwise, to establish if there is significant material degradation or damage that materially increases the risk of loss. It is the Department’s position that failure to follow these guidelines may constitute an unfair trade practice under R.I. Gen Laws Chapter 27-29 Unfair Competition and Practices. If an insurer does use aerial imagery as a basis for nonrenewal, beyond complying with all statutory notification requirements, it is best practice to notify the homeowner before initiating the nonrenewal action, provide the homeowner with copies of any aerial images used in taking the action, and allow the homeowner to provide updated information or dispute the accuracy of the imagery used. Insurers are encouraged to issue loss control recommendations and provide homeowners with reasonable time to make needed repairs before taking other action, such as nonrenewal. If aerial or satellite imagery is used in the settlement of a claim, those images must provide a clear, accurate, and current view of the property. Images of insured property that are lowresolution, out-of-focus, blurry, or not current do not provide an accurate and clear representation of the property, and thus cannot alone be used to determine a claim settlement or denial. Failure to follow these standards may constitute a violation of R.I. Gen Laws Chapter 9.1 Unfair Claims Settlement Practices Act. Lastly, the Department reminds insurers that this bulletin applies to not only their direct use of aerial imagery, but also the use of any third-party roof scores or similar mechanism that leverage aerial imagery to generate the information provided to the insurer. The Department can be contacted regarding questions or concerns about this Bulletin via email at dbr.insurance@dbr.ri.gov. Elizabeth Kelleher Dwyer Superintendent of Insurance August 18, 2025