A Rowayton seller sitting down this month to fill out a residential property condition report is dealing with a new section that didn't exist a year ago. Connecticut's Public Act 25-33 took effect July 1, 2026, and it requires sellers and landlords to disclose a property's FEMA flood zone, its known flood history, and whether it carries a FEMA elevation certificate. Fill out that section accurately and completely, and a seller has met the letter of the law.
Here's the part the form doesn't cover. A buyer touring that same house can go home, type the address into a free tool the state itself built, and see a risk picture that includes rainfall flooding the FEMA maps behind that disclosure form were never designed to capture. The law closed one information gap. It left a second one wide open, and in a town with as much coastline as Norwalk, that second gap is where the real friction lives.
Two new rules, one narrow scope
Public Act 25-33 is the headline change, but it arrived alongside a second, quieter one. Connecticut General Statutes Section 49-7b, amended through legislation signed in May 2026, now requires mortgage lenders to give borrowers a written flood notice at least ten days before closing. That notice has to say plainly that standard homeowners insurance does not cover flood damage, that flooding can happen even outside a mapped zone, and that the borrower may want to talk to a licensed insurance producer about coverage.
Put the two together and here is what a Norwalk transaction now generates on paper: a seller disclosure naming the FEMA zone and flood history, and a lender notice reminding the buyer that the zone isn't the whole story. Both are mandatory. Both are also built entirely around FEMA's official flood maps, and those maps have a known blind spot.
The wider picture nobody has to put in writing
Earlier this year, the Connecticut Insurance Department, working with the risk modeling firm First Street, rolled out a free public tool that lets anyone enter a Connecticut address and see property-specific flood, fire, wind, and heat risk. Interim Insurance Commissioner Josh Hershman has been clear about what the tool is and isn't. As reported by Insurance Journal, Hershman describes the portal as informational only, saying it does not change insurance requirements or zoning rules.
But informational doesn't mean quiet. According to reporting from Insurance Journal, First Street's model identifies roughly 81,000 more Connecticut properties facing severe flood risk than FEMA's maps show, largely because FEMA doesn't map localized flooding driven by heavy rainfall the way it maps river and coastal flooding. A house that sits outside a FEMA Special Flood Hazard Area, and therefore outside the mandatory disclosure requirement, can still show meaningful exposure on the state's own tool.
That's the mismatch. Norwalk buyers in 2026 aren't waiting for the seller's paperwork to form an opinion about flood risk. Many are checking the state portal before they ever see the disclosure form, which means the legally required half of the picture and the practically available half are no longer the same document.
| Mandatory seller disclosure (PA 25-33) | Free state risk portal (CID + First Street) | |
|---|---|---|
| Who has to check it | Completed by the seller, delivered with the condition report | Anyone, anytime, no transaction required |
| What it covers | FEMA zone status, known flood claims, elevation certificate | Modeled flood, fire, wind, and heat risk specific to the parcel |
| What it's based on | FEMA Flood Insurance Rate Maps | Rainfall-inclusive modeling that also captures flooding FEMA doesn't map |
| Legal weight | Required as part of the transaction | Explicitly informational, per the state's own description |
Why this lands harder in Rowayton than most of Fairfield County
Norwalk's coastline runs through Norwalk Harbor, the Five Mile River, and the open Sound, and Rowayton sits largely inside FEMA's VE and AE zones, where flood insurance isn't optional for a federally backed mortgage. Local market guidance puts realistic annual flood insurance costs for Rowayton waterfront property in the $12,000 to $20,000 range, and under FEMA's Risk Rating 2.0 pricing system, that number is set property by property rather than zone by zone. Elevation, distance to water, and rebuild cost all factor in, which means two houses on the same Rowayton street can carry noticeably different premiums even with identical zone designations.
That variability is exactly what makes the wider risk picture matter more here than in an inland town. A buyer comparing a Rowayton waterfront colonial to a similarly priced home in East Norwalk near Calf Pasture isn't just comparing purchase price. They're comparing two different insurance conversations, and the state's broader risk tool is often where that conversation starts now, whether or not it shows up in the transaction file.
One Fairfield County agent quoted in Bloomberg's coverage of the new portal offered a useful caution: risk models work best as a starting point for a conversation, not as a final verdict on a house. That's worth remembering on both sides of a Norwalk deal. A model flagging elevated risk doesn't mean a home is uninsurable or a bad buy. It means the insurance quote deserves to happen early, not after the inspection contingency has already expired.
The renovation ceiling the disclosure form never mentions
Norwalk's own zoning code, Article 6, includes a rule that matters more to buyers eyeing a fixer near the water than almost anything on the new disclosure form. If a structure in a flood hazard zone is not fully flood compliant, the city tracks the cumulative cost of every repair, reconstruction, or improvement over a rolling five-year period. Once that spending reaches 25 percent of the structure's market value, as determined by the Norwalk Tax Assessor, the home has to be brought into full flood compliance before any further work can proceed. The city tracks this whether or not a zoning permit was ever pulled.
For a buyer planning to update a Rowayton or East Norwalk property in phases, that threshold is easy to cross without noticing, especially on an older shingle-style home where the assessed value is modest relative to renovation costs. It's a detail worth pricing into a purchase decision before an offer goes in, not after a contractor is midway through a kitchen.
The timing detail that catches people at the closing table
There's one more piece of friction that neither the seller disclosure nor the lender notice fully solves, and it's simple: new NFIP flood insurance policies carry a standard 30-day waiting period before coverage takes effect. If a buyer's insurance shopping starts only after the lender's mandatory ten-day pre-closing notice lands, there isn't enough runway to bind a policy before closing. The smarter sequence is to request flood insurance quotes as soon as a Norwalk waterfront property goes under contract, using both the FEMA zone from the disclosure and the broader risk profile from the state portal to get an accurate number, not just an estimate based on zone alone.
What this means for a fall 2026 Norwalk transaction
The new disclosure law didn't invent flood risk information. It legalized the narrower half of it. FEMA zones, flood history, and elevation certificates now have to be in writing, and that's a real improvement over the old system. But buyers in Rowayton, SoNo, and East Norwalk already have access to a wider risk picture through the state's own tool, and treating the mandatory form as the complete answer is where sellers get surprised at the negotiating table and buyers get surprised at the insurance quote.
The better approach, for a seller preparing to list or a buyer preparing to write an offer, is to look at both documents before either one becomes urgent. Pull the FEMA zone. Check the state portal for the same address. Get an actual insurance quote instead of an assumption based on the zone letter. None of that changes what the law requires, but it changes how few surprises show up after the inspection period closes.
A few questions we hear often
Does this disclosure only apply to waterfront homes? No. The condition report requirement applies statewide to residential properties regardless of flood zone, though the practical stakes are higher for homes in or near a Special Flood Hazard Area.
If my Norwalk home isn't in a FEMA flood zone, do I need flood insurance? Federal law doesn't require it outside a Special Flood Hazard Area, but a lender can still ask for it, and Risk Rating 2.0 premiums exist regardless of zone designation. It's worth getting a quote rather than assuming a Zone X designation means no cost.
Are the FEMA maps Norwalk uses up to date? FEMA posted preliminary updated flood maps for Fairfield County in 2024, and as of recent reporting those maps were still moving through the comment and appeal process rather than fully adopted. Buyers and sellers dealing with a borderline zone designation should ask whether the preliminary maps could affect that specific parcel before treating the current map as final.
Flood disclosure rules are new enough in Connecticut that most of this market is still learning where the gaps sit. If you're weighing a purchase near Norwalk's harbor or the Five Mile River, or preparing to list a waterfront property this fall, the Kelly Higgins Team can walk through both the required paperwork and the fuller risk picture before you're under contract. Contact the team for a no obligation consultation about your home or move.