Court Requires Sworn Proofs for Supplementary Flood Claims

Policyholders must now submit formal sworn statements for all additional flood claims to ensure valid payment processing.

Updated on Oct. 30, 2026 in Insurance

Bold flat-color editorial illustration depicting a solitary, massive steel pillar, symbolizing the rigid procedural requirements of federal insurance policy. — A federal appeals court ruled that policyholders must submit sworn proofs for all supplementary flood insurance claims, tightening documentation requirements nationwide. AI Illustration. Upload story photo >

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A federal appeals court has ruled that policyholders must submit a sworn proof of loss for every supplementary insurance claim, rejecting the use of contractor invoices as a substitute. This decision impacts how households and associations manage additional flood damage claims under the National Flood Insurance Program.

Why it matters

Because the National Flood Insurance Program involves federal funds, the court mandates strict adherence to procedural requirements for each claim. This ruling ensures that policyholders cannot bypass the sworn statement requirement, even when supplementary costs are backed by contractor invoices.

The court confirmed that a condo association managing 11 buildings must provide individual sworn proofs of loss for supplementary claims, rather than relying on contractor invoices alone.

The players

Hartford Insurance Company of the Midwest

An insurance provider that participates in the National Flood Insurance Program as a servicing carrier.

Federal Emergency Management Agency (FEMA)

The federal agency that administers the National Flood Insurance Program, which provides flood coverage for millions of U.S. households.

The details

Under federal regulations, the National Flood Insurance Program requires a specific, signed, and sworn statement to validate the exact dollar amount requested in a claim. The court determined that waivers previously granted for an initial proof of loss do not automatically apply to subsequent requests for more money. Consequently, policyholders must treat every supplementary claim as a new documentation requirement rather than an extension of a prior approval.

Hurricane Ian caused flooding at the condominium buildings in September 2022.
FEMA issued waivers for original proofs of loss in November 2023.
The federal appeals court issued its ruling on October 23, 2026.

Money Landscape

This ruling reinforces the rigid procedural standards inherent to the National Flood Insurance Program, which relies on federal treasury funds. It serves as a reminder that claims processes for government-backed programs are bound by specific, fixed regulations that leave little room for informal alternatives.

Policyholders filing supplementary claims must ensure they submit a formal, sworn proof of loss for every specific amount requested to remain compliant with federal requirements. Consult with a qualified professional to ensure all necessary documentation is correctly filed for your flood insurance claims.

The takeaway

Always prioritize formal documentation requirements over informal proofs like contractor invoices when dealing with federal insurance programs. Keep a detailed log of all correspondence and sworn filings related to your flood damage to ensure your claims remain valid under federal regulations.