Overview

The Climate Risk Reporting in the U.S. Insurance Sector benchmark series, initiated in 2023 with annual assessments covering reporting years from 2021 onwards, evaluates how U.S. insurance companies disclose climate-related financial risks and opportunities using the Task Force on Climate-related Financial Disclosures (TCFD) framework. The series examines reporting across governance, strategy, risk management, and metrics and targets, providing a consistent view of climate disclosure practices within the insurance sector.

Purpose of the benchmark series

The purpose of the benchmark is to assess the maturity, completeness and quality of climate-related disclosures submitted through the National Association of Insurance Commissioners (NAIC) Climate Risk Disclosure Survey. It is intended to help regulators, insurers, investors and other stakeholders understand how climate risks are incorporated into governance structures, risk management processes and strategic decision-making within the insurance industry.

Methodology

The series analyses insurer responses to the NAIC Climate Risk Disclosure Survey and assesses their alignment with the TCFD framework. Reporting is evaluated across the four TCFD pillars: governance, strategy, risk management, and metrics and targets.

The methodology has evolved from a binary assessment of whether disclosures addressed specific TCFD recommendations to a more detailed qualitative assessment that evaluates the specificity, completeness and decision-usefulness of reported information. The analysis uses machine-learning and large language model-based tools developed by Manifest Climate to assess disclosures against a structured set of climate-reporting datapoints and framework requirements.

Relevance for finance professionals

Finance professionals can use this benchmark series to evaluate climate-related financial risk disclosure practices across the insurance sector and to understand evolving expectations for climate-risk reporting. The series provides a reference point for assessing alignment with recognised disclosure frameworks, comparing reporting approaches among insurers, and monitoring the integration of climate-related considerations into governance, risk management and financial decision-making processes.