Valencia, SpainRC/RS/2026/OP.2
26 October 2026
Who I am and what happened
To the members of the Resilience Council,
I am Xoán López Casal, Rapporteur of the Resilience Council, writing from Valencia. I offer this opinion on RS-001, the proposed Reopen Standard, in the wake of the Council’s review of business closures and reopening after disasters. I write as a member of this Assembly and as someone for whom floods are not an abstract category in a report. I will not name a business, identify what it sells, or present a personal loss figure. The point of this letter is the sequence that follows a flood: a business is interrupted; the owner must understand what can be salvaged and what must stop; income may cease while obligations continue; and reopening depends on decisions and resources arriving in a usable order.
That sequence matters because “recovery” is often treated as a single endpoint. For a small business, it is several linked questions. Can the owner safely reopen? Is there enough cash to pay for urgent work and keep essential obligations current? Has an insurer made a decision that can be acted upon? Is there practical help to plan continuity while uncertainty remains? A delay in one part can make the others harder. A decision after the point when it could have prevented closure may still be a decision, but it is not timely resilience.
I do not argue that every flood produces the same loss or that every claim can be decided from the same evidence. I argue that the standard should recognise a common practical need: after a declared disaster, small businesses need a prompt path to an answer, temporary liquidity, and help planning what comes next. A standard that speaks only of eventual reimbursement overlooks the period in which reopening is won or lost.
What the evidence shows
The Council’s data as of 26 October 2026 record 1,780 members in 49 countries and 5,430 reports from 50 countries. The reports are distributed across the seven councils as follows: Platform, 1,962; Cashflow, 1,358; Fair Play, 712; Trade, 535; Resilience, 380; Red Tape, 305; and Team, 178. Those figures describe the Assembly’s evidence base, not a census of all affected businesses. They should be read as a structured set of member reports, not as a claim that every business has the same experience.
Within the Resilience Council, 154 members are in 47 countries. The Council has 380 reports from 49 countries, with a median amount at stake of approximately US$3,968. All 380 reports identify a disaster as the situation. The most reported countries are the United States, 66; Spain, 24; Canada, 24; the Philippines, 23; the United Kingdom, 18; India, 16; Japan, 16; and Mexico, 15. In the reported team sizes, 36% say “Just me,” 45% have 2–9 people, 16% have 10–49, and 3% have 50–249. There were 106 reports in the 30 days preceding the data cut-off.
These numbers do not, by themselves, prove that a particular insurer or public authority has failed to act within a particular period. They do show why a standard designed for small firms must account for very small teams, modest but consequential amounts at stake, and reports spanning many countries. For an owner working alone or with a handful of colleagues, the time spent pursuing information, assembling paperwork, and waiting without an answer is not separate from the business’s recovery capacity. It consumes that capacity.
The Council’s pattern review update, RC/RS/2026/N.2, records that four of the five pattern tests have been met and that corroboration remains pending. That qualification is important. Volume, Frequency, Consistency, and Spread have met the Council’s threshold; the fifth test has not yet been completed. I support taking the evidence seriously without claiming that the outstanding test has been satisfied. The proposed fix is a response to a clear recurring pattern, while the Council continues to seek corroboration.
External evidence points in the same direction. UNDRR reports that small and medium-sized enterprises bear approximately 75% of business disaster losses, and that disaster risk reduction can reduce losses by up to a third.1 A UNDRR report citing a Japan METI survey states that 8% of prepared SMEs had not recovered sales, compared with 19% of unprepared SMEs.2 These findings do not establish that a 30-day claims decision or 10-day bridge-funding period will produce a specific recovery rate. They support a more measured conclusion: preparedness and continuity matter, and recovery arrangements should not leave small firms to face avoidable delay without help.
The case for a time standard is therefore not that a deadline eliminates disaster loss. It is that a deadline makes the response legible and gives owners a point at which they can plan. The case for bridge funding is not that every reported amount should be paid without scrutiny. It is that a temporary gap between damage and a final insurance or public-aid decision can itself threaten the ability to reopen. The case for continuity support is not that a plan prevents every closure. It is that preparation and practical guidance can help an owner make decisions before and after disruption.
How the law in my country and elsewhere handles it
The materials before this Council do not set out Spanish statutory deadlines for insurers to decide disaster claims, or statutory deadlines for public disaster aid to reach micro businesses. I will not infer that no such rules exist, or describe their content without evidence in this dossier. From Valencia, I can speak to the importance of the question; I cannot use this opinion to certify the details of Spanish insurance or aid law. The Council should seek country-specific legal review before presenting RS-001 as a statement of any national law.
The international framework identified in the Council’s materials is the Sendai Framework for Disaster Risk Reduction 2015–2030. Paragraph 30(o) calls for business continuity to be integrated into business practice, particularly for micro, small and medium-sized enterprises; paragraph 36(c) likewise recognises the role of businesses, with attention to MSMEs.3 These provisions give a policy basis for treating continuity as part of resilience. They do not, on the information supplied to this Council, set a 30-day insurance decision deadline or a 10-day bridge-funding deadline.
That distinction matters. A framework can set direction and encourage preparedness without furnishing an owner with a date by which a claim decision or emergency payment must arrive. RS-001 would be a proposed standard, not a claim about what the Sendai Framework already requires. Likewise, the Japan METI survey is evidence about preparedness and sales recovery, not a law establishing a deadline. The Council should keep those categories separate: legal obligations where verified; international policy commitments as such; and the additional standard that members are asking institutions to adopt.
In my view, the absence of country-specific law in this dossier is not a reason to avoid setting out a common proposal. It is a reason to phrase it accurately. The Council can ask insurers, public agencies, and other relevant institutions to adopt a clear, measurable practice while recognising that national implementation may need to fit existing law. The proposal should not pretend that current rules are uniform across countries, and it should not weaken a stronger right that already exists in any jurisdiction.
The strongest argument against my view and my answer
The strongest argument against fixed timelines is that disasters and claims differ. Damage may be extensive, records may be lost, access may be restricted, and a claim may involve disputed facts or several parties. A firm 30-day deadline could encourage a rushed decision, disadvantage a claimant whose evidence is difficult to obtain, or push the cost of rapid review into premiums. A public authority may also be unable to provide bridge funding within 10 days if the disaster declaration is delayed, funding is limited, or eligibility cannot yet be checked. A standard that ignores those constraints could be unrealistic and could create an appearance of protection without reliable delivery.
This is a serious objection. A time limit should not require an insurer to invent certainty, nor should an emergency advance be confused with a final finding about liability or the full value of a loss. My answer is to define what the clock requires. The 30-day period should require a reasoned claim decision or a clear notice identifying what remains unresolved, why it matters, and when the next review will occur. It should not compel a false finality where essential evidence is genuinely unavailable. Any extension should be limited, explained to the claimant, and recorded, rather than becoming an indefinite pause with no accountable next step.
Similarly, bridge funding should be designed as temporary support, with transparent eligibility and a simple means of confirming that a micro business has been affected by a declared disaster. It should not decide the ultimate insurance claim or public entitlement. A mechanism can provide a timely initial assessment and communicate promptly when a payment cannot be made, including the reason and the route to review. The details will differ among jurisdictions, but the principle is stable: uncertainty should be managed openly, not transferred silently to the owner through weeks of unexplained waiting.
There is also a concern that a standard could favour businesses with better records, greater administrative capacity, or easier access to advisers. That concern strengthens the case for continuity support. A standard should be usable by an owner working alone, not only by a business able to hire someone to navigate the process. Plain-language instructions, a short list of essential information, a named point of contact, and accessible routes for follow-up are not extras. They are how a deadline becomes meaningful in practice.
Finally, a standard must not overstate what the Council’s evidence proves. Corroboration remains pending. We should not claim that every delay caused a closure, or that one timetable fits every disaster. But uncertainty about the size of an effect does not erase the recurring need reported across countries. It calls for careful design, transparent monitoring, and revision as better evidence arrives—not for a proposal so vague that no one can tell whether it has been met.
My position clause by clause
First, insurance claims decided within 30 days. I support this clause. The standard should define when the period begins, require prompt acknowledgement, and provide a written decision within 30 days of receiving the claim or the minimum information needed to assess it. Where a decision cannot responsibly be completed, the institution should explain the missing information, the reason it is material, and a specific next review date. An extension should be exceptional, proportionate, and visible to the claimant. The objective is a usable decision or an accountable explanation—not a promise that every complex claim will be fully resolved on an identical timetable.
Second, bridge funding within 10 days of a declared disaster. I support this clause, with a clear distinction between bridge support and final compensation. The 10-day period should begin from the relevant disaster declaration, as RS-001 proposes, and the process should be designed so an owner can apply without first completing a full insurance investigation. The standard should identify the responsible institution, basic eligibility, the information required, and how a decision or delay will be communicated. It should also state how temporary funding is reconciled with later decisions, so that support is predictable and fair. The Council should invite public authorities to identify workable routes in their own systems rather than assume that one administrative model can be transplanted everywhere.
Third, continuity planning support for micro businesses. I support this clause without qualification as a necessary part of the standard. Support should be practical, short, and accessible before and after a disaster: help to identify critical operations and dependencies, prepare a simple continuity plan, and understand immediate reopening steps. It should not require an owner to produce a complex document as a condition of receiving urgent help. For a one-person business, continuity support must fit the scale of the operation. For a small team, it should help owners assign responsibilities and keep essential information accessible. The aim is useful preparation, not paperwork for its own sake.
Taken together, the clauses should form one sequence: prepare; acknowledge and decide; provide temporary help where eligible; and support reopening. The standard should say who is responsible at each stage and should require plain reporting on whether the timelines were met. It should preserve national legal protections, allow justified and documented exceptions, and be reviewed against evidence from owners across different disaster settings. That is how the Council can be ambitious without being careless.
What I ask
I ask members of the Resilience Council to support RS-001 as a standard with the safeguards described above. I ask the Assembly to recognise that a decision made after the useful moment may be procedurally complete yet practically inadequate for a micro business trying to reopen. And I ask those who will receive the eventual letters to treat the timelines not as a demand for automatic payment in every case, but as a demand for an answer, an accountable process, and support that arrives while it can still matter.
As the Council completes the fifth pattern test, we should continue to seek corroboration and gather evidence on days to decision, days to funding, and days to reopening. We should report what we know and what we do not know. We should not promise that the Reopen Standard will prevent every closure. We can say that resilience is weakened when owners are left without a decision, temporary support, or practical guidance at the moment each is needed.
My view is that the future fix must contain all three elements in RS-001: an insurance claim decision within 30 days, bridge funding within 10 days of a declared disaster, and continuity planning support for micro businesses. It must make the first two timelines clear and accountable, distinguish temporary support from a final claim outcome, and make the third element genuinely accessible to the smallest firms. A standard that omits any one of these leaves a gap between damage and reopening. That is the gap the Council should ask institutions to close.
Respectfully,
Xoán López Casal
Rapporteur, Resilience Council
Valencia, Spain