The Tennessee Department of Commerce and Insurance (TDCI) has told insurers that aerial imagery — including drone and satellite photos — cannot be the only basis for claim, roof-replacement or nonrenewal decisions. The bulletin from Insurance Commissioner Carter Lawrence follows homeowner complaints in Tennessee and similar bulletins in Alabama and West Virginia.
What does the TDCI bulletin actually say?
Three things, in the department's own framing:
- If a bird's-eye image does not accurately reflect the condition of a roof, the image alone is not sufficient to require a roof replacement.
- If an image's accuracy is uncertain — older shots, blurry or out-of-focus images — the insurer should physically inspect the property or obtain the information another way.
- "Denying a claim based solely on unclear or imprecise aerial images that do not accurately reflect the current state of the subject property constitutes an unfair claims practice in violation of Tenn. Code Ann. § 56-8-105."
Can I see the photo my insurer used?
Yes — that is the part homeowners most often do not know. TDCI told insurers to keep aerial images on file and make them available to insureds on request. If a homeowner files a complaint with the department, both the department and the homeowner are entitled to view the evidence the insurer relied on.
Is TDCI banning drones?
No. The department was explicit that it is not trying to limit the use of drone and satellite images. The issue is sole reliance on an image that may be stale or unreadable, and the decisions that follow it — a denied claim, a demand to replace a roof at your expense, or a nonrenewal notice weeks before hurricane-remnant season.
| What the bulletin covers | Where you stand |
|---|---|
| Claim denied solely on unclear aerial image | Unfair claims practice under Tenn. Code Ann. § 56-8-105 |
| Roof replacement demanded from an image | Image alone is not sufficient if it does not show current condition |
| Uncertain or outdated image | Insurer should physically inspect or gather other information |
| Your right to the image | Insurers must retain images and provide them on request |
| Complaint route | TDCI — homeowner and department may view the insurer's evidence |
| Other states with similar guidance | Alabama, West Virginia |
What to do if you get one of these letters
- Ask in writing for the imagery the decision was based on, plus the date it was captured.
- Check the date. A photo taken before your last roof repair is not evidence of current condition.
- Request a physical inspection and document the roof yourself with dated photos from the ground.
- Keep invoices. A roof replacement or repair receipt beats a satellite pixel every time.
- File with TDCI if the carrier will not produce the image or reconsider. The bulletin gives you the standard to cite.
Why this is happening now
Aerial underwriting has gotten cheap, and carriers use it to re-inspect entire books between renewals. In a state where wind and hail drive losses, roofs are the exposure carriers most want to see — and East Tennessee roofs age under tree cover, shade and moss that read badly from 400 feet. The technology is not going away, so the protection is procedural: ask for the image, ask for the date, ask for an inspection.
Sources: Tennessee Department of Commerce and Insurance bulletin on the use of aerial imagery, Commissioner Carter Lawrence; Insurance Journal, April 8, 2026; The Daily Times, April 24, 2026; Tenn. Code Ann. § 56-8-105.
