TCFD Alignment Lessons from the Insurance Industry

Three tips to overcome TCFD disclosure gaps
TCFD Alignment Lessons from the Insurance Industry
Publ. date 29 Jul 2022
As more and more organizations are embarking on the TCFD journey and with the proposal for updating the ESRS being submitted which will incorporate alignment with TCFD, the extent to which organizations will be held accountable for integrating the recommendations will only increase. This article outlines why it is important for insurance companies to be aware of and develop an understanding of climate-related risks and opportunities, provides best practice examples of insurance companies implementing the TCFD recommendations, and suggests three tips for closing the gaps in TCFD alignment.

According to a benchmarking study conducted by Finch & Beak aimed at understanding the ESG challenges facing the 25 largest Dow Jones Sustainability Index invited European insurance companies, 41% of companies cited climate change as one of their most material risks.

The Task Force on Climate-Related Financial Disclosures (TCFD) has developed a framework that aims to help public companies and other organizations to disclose climate-related risks and opportunities. It does this through four core recommendations that are related to governance, strategy, risk management and targets and metrics.

By aligning with TCFD the Insurance industry can become more aware of, identify and understand climate-related risks and capitalize on opportunities. For overall recommendations on how to approach TCFD see the recently published Finch & Beak article The TCFD Journey: A Roadmap.

Mapping alignment with TCFD recommendations

Through evaluating a sample of 10 of the top 25 European insurance companies selected for varying sustainability strategy maturity, it becomes clear that the application of TCFD principles is not uniform across the 4 key themes. When it comes to the governance dimension, there is a clear discrepancy in how the companies are describing the way in which management and Boards are involved in the evaluation of climate-related risks and opportunities. As part of their public reporting, 60% of the sampled insurance companies solely mention that the Board is informed on some climate issues or the overall risk profile.

Phoenix Group Holdings provides a strong case study of a best practice in this respect. Beyond assigning clear responsibility of oversight of the Group’s approach to climate risk and opportunity to the Board Sustainability Committee and oversight of the identification, assessment, management, and reporting of climate-related risks to the Board Risk Committee, Phoenix Group conducted training on regulatory requirements for TCFD, climate scenario analysis, and approaches to climate-related metrics and targets.

As part of the evaluation of the strategy dimension, 90% of the sampled companies in the Insurance industry provide in-depth explanations of the impact of climate-related risks and opportunities on the business, strategy, and financial planning in public reporting. The gap lies in identifying these risks and opportunities over various time frames (i.e., short, medium, and long term). In order to fully understand the risk, it is imperative that the companies are modeling out various climate scenarios (i.e. hothouse world vs. orderly transition) over several time frames (short-, mid-, and long-term) to truly understand the current risk and how it may evolve as applied to the company’s business strategy.

Companies are advised to clearly define timeframes and disclose the scenarios used to increase clarity as Allianz has done in listing out all aspects covered, scenarios used, and the scenario provider. The company has defined the short term as up to 3 years, the medium term as 3 to 10 years and the long-term as 10 plus years. The company then takes another step further and along 5-year increments from 2020 to 2040, it evaluates the asset and business impact under two transition scenarios as well as including risk enhancers and risk mitigators in the final analysis. This analysis is then integrated into the wider enterprise risk management framework which is considered a best practice. 70% of the sample followed suit in noting that the process for climate risk management is integrated within the larger enterprise risk management framework. Such performance on the risk management aspect is not surprising for an industry that has long been proficient in risk modeling as a part of both its business model and investing strategy.

The final dimension that is appraised is the metrics and targets, which is the dimension that seeks to identify how the organization discloses the metrics it uses to assess climate-related risks and opportunities, disclosing emissions and the related risks, and the targets used to manage climate-related risks and opportunities and performance against targets. The industry performs particularly poorly on disclosing its emissions and connecting them to the related risks. Only 40% of companies clearly disclose their own emissions and identify this as a climate risk. Often, the emissions are reported seemingly in isolation, like in the GRI Annex, and not acknowledged in how this lines up with the company strategy. Furthermore, the targets that are used to manage the risks and opportunities are often vague and not clearly linked to mitigating risks.

Generali serves as an inspiring best practice example in the way the company highlights various metrics and targets across physical and transition risks and opportunities. This includes highlighting the decarbonization of the general account investment portfolio to make it climate neutral by 2050 and highlighting that the company decreased its carbon intensity by 11.7 compared to 2020. The company also mentions an overachieved target related to opportunities for green and sustainable investments. 

Three tips to overcome identified gaps in TCFD disclosures


  1. Fully engage with the Boardroom on climate risk: bringing the Boardroom fully up to date and up to speed can be key in ensuring that the entire risk strategy is executed properly. Given the materiality of this risk for insurance organizations, having a Board well equipped to understand and engage on this issue is crucial.
  2. Connect organization emissions to climate risk: simply reporting the carbon footprint of the company’s portfolio or emissions in an annex does not fully satisfy the depth and rigor that is recommended by TCFD. Rather, organizations are encouraged to look at emissions, including Scope 3, which while challenging for the insurance industry yields valuable insights on the risks and connect them to targets and metrics.
  3. Define and evaluate timeframes and scenarios used for climate risk: many in the industry have remained vague about exactly which types of scenarios are utilized for evaluating which aspects of climate risk and on what time horizons these risks are analyzed on. For stakeholders (and the organization itself) to fully understand the evolution of the risk, this is a foundational step.

The downloadable Finch & Beak TCFD Roadmap available at the top of this article, is a useful tool to help your organization close these three or similar gaps and assist you in successfully implementing the recommendations.

Finch & Beak provides TCFD and climate strategy support

At Finch & Beak, our purpose is to accelerate sustainability within the business of our clients. Together with our fellow companies from SLR Consulting, we offer a wide range of TCFD and climate support services.

If your organization is considering expanding your climate scenario analysis, or taking your climate-related financial disclosures to the next level then reach out to Johana Schlotter, at or call +31 6 28 02 18 80 to discuss how Finch & Beak can support you. 

Photo by Caleb Jones on Unsplash

About Claire Carter

Sustainability professional aiming to help companies implement practical strategies yielding positive ESG results.

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