OPINION
VOSS, Presiding Judge.
This is a consolidated appeal from three separate cases filed in Maricopa County Superior Court.
Appellants each filed a complaint against the State of Arizona, the Arizona Department of Insurance, and Susan Gallinger, Director of Insurance of the State of Arizona, alleging that each appellee failed to properly supervise and regulate AMS Life Insurance Company (AMS). Specifically, appellants allege that appellees approved an application submitted by AMS to redomesticate to Arizona at a time when appellees knew AMS was not qualified to write insurance under the laws of Arizona; that appellees approved AMS’s annual request for renewal of its certificate of authority when AMS did not meet Arizona’s statutory requirements; and that appellees were grossly negligent in licensing and regulating AMS. Appellants further contend that these failures caused them economic harm when AMS went into receivership.
In each of the three actions, the trial court granted appellees’ motion to dismiss for failure to state a claim on the ground that appellees were entitled to absolute immunity under Arizona Revised Statutes Annotated section (A.R.S. § ) 12-820.01.1
DISCUSSION
When reviewing a trial court’s dismissal for failure to state a claim, we must assume that all allegations of the claim are true. Jung v. City of Phoenix, 160 Ariz. 35, 35-36, 770 P.2d 339, 339-40 (App.1987), modified, 160 Ariz. 38, 770 P.2d 342 (1989). We will uphold the dismissal only if plaintiff “would not be entitled to relief under any facts susceptible of proof in the stated claim.” Menendez v. Paddock Pool Constr. Co., 172 Ariz. 258, 261, 836 P.2d 968, 971 (App.1991). Whether defendants are entitled to immunity is a question of law which this court reviews de novo. Carroll v. Robinson, 178 Ariz. 453, 456, 874 P.2d 1010, 1013 (App.1994).
The only issue on appeal is whether the appellees are entitled to absolute immunity under A.R.S. § 12-820.01. We find they are.
In Stone v. Arizona Highway Comm’n, 93 Ariz. 384, 392, 381 P.2d 107, 112 (1963), the Arizona Supreme Court reversed the prior common law and abolished governmental immunity. The supreme court revisited its Stone decision in Ryan v. State, 134 Ariz. 308, 656 P.2d 597 (1982). In Ryan, the court acknowledged that a total abolition of governmental immunity was not a workable solution and that some areas of immunity must remain. Id. at 310, 656 P.2d at 599. The court stated that immunity should be recognized for judicial and legislative functions but had difficulty defining the appropriate scope of immunity for executive functions. Id. at 310-11, 656 P.2d at 599-600. The court recognized that an ad hoc approach was the most appropriate way to determine immunity for executive functions. Id. at 310, 656 P.2d at 599. The court invited the legislature to intervene in the development of governmental immunity by defining which executive functions should be entitled to immunity. Id. at 310, 656 P.2d at 599.
The legislature responded by enacting immunity statutes in 1984. See A.R.S. §§ 12-820 to 12-820.05. The statutes alter the existing law of governmental immunity only “as specifically provided in this article.” A.R.S. § 12-820.05(A). Therefore, for governmental immunity to apply, the conduct must be within a specific statutory exception to the rule of governmental liability. Such is the ease here.
[286]*286A.R.S. § 12-820.01 provides absolute immunity for certain governmental functions.2 Absolute immunity is provided for the exercise of judicial or legislative functions and the exercise of administrative functions “involving the determination of fundamental governmental policy.” A.R.S. § 12-820.01(A). The statute does not define what functions involve the determination of fundamental governmental policy other than to say that the function must involve the exercise of discretion. A.R.S. § 12-820.0KB). Therefore, to be entitled to absolute immunity under A.R.S. § 12 — 820.01(A)(2), a governmental function must involve both the determination of fundamental governmental policy and the exercise of discretion.
We first observe that the licensing and regulation of insurance involves the exercise of substantial discretion. The language of A.R.S. Title 20 gives the Director of Insurance and the Department of Insurance discretion throughout the licensing and regulatory scheme. For example, the Director of Insurance has discretion to specify standards for the valuation of an insurer’s reserves, A.R.S. § 20-510(C)(2)(c) (Supp.1995), may accept an insurer’s calculation of reserves, A.R.S. § 20-510(B), may require an insurer to submit statistical and financial data, A.R.S. § 20-235(C), may conduct investigations deemed proper to determine whether a person has violated any portion of A.R.S. Title 20, A.R.S. § 20-142(C), and may hold hearings for any purpose deemed necessary, A.R.S. § 20-161(A). Additionally, the courts of other states have recognized that the exercise of discretion permeates the regulation of insurance companies. Alias Smith & Jones, Inc. v. Barnes, 695 P.2d 302, 306 (Colo.App. 1984); Hatcher v. Haupert, 655 N.E.2d 1229, 1232 (Ind.App.1995); Gerber v. Commissioner of Ins., 242 Mont. 369, 786 P.2d 1199, 1200 (1990); Zuber v. Department of Ins., 34 Ohio App.3d 42, 516 N.E.2d 244, 247 (1986); First Nat’l Bank v. Pennsylvania,
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OPINION
VOSS, Presiding Judge.
This is a consolidated appeal from three separate cases filed in Maricopa County Superior Court.
Appellants each filed a complaint against the State of Arizona, the Arizona Department of Insurance, and Susan Gallinger, Director of Insurance of the State of Arizona, alleging that each appellee failed to properly supervise and regulate AMS Life Insurance Company (AMS). Specifically, appellants allege that appellees approved an application submitted by AMS to redomesticate to Arizona at a time when appellees knew AMS was not qualified to write insurance under the laws of Arizona; that appellees approved AMS’s annual request for renewal of its certificate of authority when AMS did not meet Arizona’s statutory requirements; and that appellees were grossly negligent in licensing and regulating AMS. Appellants further contend that these failures caused them economic harm when AMS went into receivership.
In each of the three actions, the trial court granted appellees’ motion to dismiss for failure to state a claim on the ground that appellees were entitled to absolute immunity under Arizona Revised Statutes Annotated section (A.R.S. § ) 12-820.01.1
DISCUSSION
When reviewing a trial court’s dismissal for failure to state a claim, we must assume that all allegations of the claim are true. Jung v. City of Phoenix, 160 Ariz. 35, 35-36, 770 P.2d 339, 339-40 (App.1987), modified, 160 Ariz. 38, 770 P.2d 342 (1989). We will uphold the dismissal only if plaintiff “would not be entitled to relief under any facts susceptible of proof in the stated claim.” Menendez v. Paddock Pool Constr. Co., 172 Ariz. 258, 261, 836 P.2d 968, 971 (App.1991). Whether defendants are entitled to immunity is a question of law which this court reviews de novo. Carroll v. Robinson, 178 Ariz. 453, 456, 874 P.2d 1010, 1013 (App.1994).
The only issue on appeal is whether the appellees are entitled to absolute immunity under A.R.S. § 12-820.01. We find they are.
In Stone v. Arizona Highway Comm’n, 93 Ariz. 384, 392, 381 P.2d 107, 112 (1963), the Arizona Supreme Court reversed the prior common law and abolished governmental immunity. The supreme court revisited its Stone decision in Ryan v. State, 134 Ariz. 308, 656 P.2d 597 (1982). In Ryan, the court acknowledged that a total abolition of governmental immunity was not a workable solution and that some areas of immunity must remain. Id. at 310, 656 P.2d at 599. The court stated that immunity should be recognized for judicial and legislative functions but had difficulty defining the appropriate scope of immunity for executive functions. Id. at 310-11, 656 P.2d at 599-600. The court recognized that an ad hoc approach was the most appropriate way to determine immunity for executive functions. Id. at 310, 656 P.2d at 599. The court invited the legislature to intervene in the development of governmental immunity by defining which executive functions should be entitled to immunity. Id. at 310, 656 P.2d at 599.
The legislature responded by enacting immunity statutes in 1984. See A.R.S. §§ 12-820 to 12-820.05. The statutes alter the existing law of governmental immunity only “as specifically provided in this article.” A.R.S. § 12-820.05(A). Therefore, for governmental immunity to apply, the conduct must be within a specific statutory exception to the rule of governmental liability. Such is the ease here.
[286]*286A.R.S. § 12-820.01 provides absolute immunity for certain governmental functions.2 Absolute immunity is provided for the exercise of judicial or legislative functions and the exercise of administrative functions “involving the determination of fundamental governmental policy.” A.R.S. § 12-820.01(A). The statute does not define what functions involve the determination of fundamental governmental policy other than to say that the function must involve the exercise of discretion. A.R.S. § 12-820.0KB). Therefore, to be entitled to absolute immunity under A.R.S. § 12 — 820.01(A)(2), a governmental function must involve both the determination of fundamental governmental policy and the exercise of discretion.
We first observe that the licensing and regulation of insurance involves the exercise of substantial discretion. The language of A.R.S. Title 20 gives the Director of Insurance and the Department of Insurance discretion throughout the licensing and regulatory scheme. For example, the Director of Insurance has discretion to specify standards for the valuation of an insurer’s reserves, A.R.S. § 20-510(C)(2)(c) (Supp.1995), may accept an insurer’s calculation of reserves, A.R.S. § 20-510(B), may require an insurer to submit statistical and financial data, A.R.S. § 20-235(C), may conduct investigations deemed proper to determine whether a person has violated any portion of A.R.S. Title 20, A.R.S. § 20-142(C), and may hold hearings for any purpose deemed necessary, A.R.S. § 20-161(A). Additionally, the courts of other states have recognized that the exercise of discretion permeates the regulation of insurance companies. Alias Smith & Jones, Inc. v. Barnes, 695 P.2d 302, 306 (Colo.App. 1984); Hatcher v. Haupert, 655 N.E.2d 1229, 1232 (Ind.App.1995); Gerber v. Commissioner of Ins., 242 Mont. 369, 786 P.2d 1199, 1200 (1990); Zuber v. Department of Ins., 34 Ohio App.3d 42, 516 N.E.2d 244, 247 (1986); First Nat’l Bank v. Pennsylvania, 102 Pa.Cmwlth. 474, 518 A.2d 871, 873 (1986).
However, a finding of discretion, alone, is not sufficient to provide absolute immunity. The act must also include the determination of fundamental governmental policy. The statutory language provides courts with little guidance in making this determination.
The history of A.R.S. § 12-820.01 likewise provides little direct guidance for the determination of what constitutes determination of fundamental governmental policy. The language of A.R.S. § 12-820.01 was patterned after Restatement (Second) of Torts § 895B. The comments to the Restatement note that the rule “expresses a standard rather than a precise rule and does little more than to offer guidelines for a court.” Restatement (Second) of Torts § 895B cmt. d. The commission that drafted A.R.S. § 12-820.01 expressed an intent to allow courts to make case-by-case determinations of whether absolute immunity applies to specific administrative functions. In its report, the commission states that it is necessary that situations involving the determination of fundamental governmental policy “be identified by the courts as they arise.” Governor’s Commission on Governmental Tort Liability, Arizona Governmental Tort Claims Act, at 11-12 (filed Dec. 16, 1983). The commission further stated that the “purpose of the immunity is ‘to insure that courts refuse to pass judgment on policy decisions in the province of coordinate branches of government’ ” where the policy decision involves “consciously balancing risks and advantages.” Id. at 12 (quoting Restatement (Second) of Torts [287]*287§ 895B cmt. d). The courts should avoid making “a policy decision that is better left to the administrative officials.” Id.
The administrative acts in this case involve policy decisions that should be reserved for administrative officials. The decision to license a particular insurance company entails considerably more than a low-level bureaucratic determination that the company meets a list of static requirements. Instead, the decision requires reliance upon the judgment and expertise of administrative officials to determine whether the applicant company is fit to conduct business in Arizona. This is the precise type of policy decision that courts should leave to administrative officials.
The legislature provides additional guidance by providing examples of administrative functions that involve the determination of fundamental governmental policy. Evenstad v. State, 178 Ariz. 578, 588, 875 P.2d 811, 816 (App.1993). A.R.S. § 12-820.01(B) provides a list of government functions that the legislature has determined, by definition, involve the determination of fundamental governmental policy. Bird v. State, 170 Ariz. 20, 23, 821 P.2d 287, 290 (App.1991). The language of the statute specifically notes that this list is not exclusive. A.R.S. § 12-820.01(B); Evenstad, 178 Ariz. at 583, 875 P.2d at 816. A non-enumerated governmental function may be entitled to absolute immunity if similar in nature and quality to an enumerated function. See Evenstad, 178 Ariz. at 583, 875 P.2d at 816.
In Evenstad, this court was asked to decide whether the Motor Vehicle Department (MVD) was absolutely immune when promulgating rules and regulations to enforce laws. Id. at 582, 875 P.2d at 815. Like the regulation of insurance, promulgation of rules and regulations is not specifically enumerated in A.R.S. § 12-820.01. The court then compared the promulgation of rules and regulations to the enumerated functions. The court held the promulgation of rules and regulations was similar to two enumerated functions: determining whether to seek or provide resources, A.R.S. § 12-820.01(B)(1), and determining whether and how to spend existing resources, A.R.S. § 12-820.01(B)(2). Evenstad, 178 Ariz. at 583, 875 P.2d at 816. Because of the similar nature of the functions, the court held the MVD was protected by absolute immunity when promulgating rules and regulations. Id. at 586, 875 P.2d at 819.
The same analysis is helpful in this case. The licensing and regulation of insurance is similar in nature and quality to the enumerated function, “[t]he licensing and regulation of any profession or occupation.” A.R.S. § 12-820.01(B)(3). The licensing and regulation of insurance involves similar policy considerations and determinations. Initially, both the regulation of insurance and the regulation of professions and occupations are done to protect the citizens of the state. Compare A.R.S. § 32-101(A) with A.R.S. § 20-101 (Historical and Statutory Notes). Additionally, the regulation of insurance and the regulation of professions and occupations both require attainment of minimum quality standards, training, and financial responsibility. In both areas, the administrative decisions involved in the licensing or regulation require specialized knowledge of the underlying industry or profession.
Finding that insurance regulation does not involve the determination of fundamental governmental policy would render meaningless the legislature’s language that the enumerated functions of A.R.S. § 12-820.01(B) are not exclusive. If regulation of one of the largest and most far-reaching industries in the state fails to involve the determination of fundamental governmental policy, what non-enumerated administrative functions could possibly be entitled to immunity protection? It would be anomalous to insulate administrative officials from errors made in carrying out minor licensing decisions, such as those involved in the licensing of barbers and security guards, while leaving exposure for errors made in regulating one of the state’s largest, most pervasive industries.
Appellants argue that because they have alleged appellees acted with gross negligence, appellees are not protected by the qualified immunity provided by A.R.S. § 12-820.02. Appellants’ claim is controlled by A.R.S. § 12-820.02(5) which provides qualified immunity to public entities or employees for “[t]he issuance of or failure to revoke or [288]*288suspend any permit, license, certificate, approval, order or similar authorization for which absolute immunity is not provided pursuant to § 12-820.01.” (Emphasis added.) This section, therefore, applies only to acts for which absolute immunity is not provided. Because we believe that A.R.S. § 12-820.01 provides absolute immunity for appellees, appellees are not liable under A.R.S. § 12-820.02(5) for their alleged gross negligence in granting and failing to revoke AMS’s certificate to conduct insurance.
CONCLUSION
We hold that A.R.S. § 12-820.01 affords absolute immunity for the licensing and regulation of insurance. The act of licensing and regulating insurance is an administrative act that involves both the exercise of discretion and the determination of fundamental governmental policy.
We affirm.
TOCI, J., concurs.