Insurance Europe

Insurance Europe has submitted its response to a consultation on the International Sustainability Standards Board (ISSB) proposed amendments to IFRS S2, which seek to make greenhouse gas emissions reporting easier.

Insurers particularly welcome the ISSB’s recognition of the challenges surrounding Scope 3 Category 15 disclosures, especially in relation to insurance-associated emissions (IAEs). While the insurance industry fully acknowledges the risks of climate change and its role in enabling the climate transition, it argues that the methodologies for calculating IAEs remain underdeveloped. Prematurely introducing mandatory IAE disclosures risks generating misleading or inconsistent data that may hinder, rather than help, effective climate action.

In its position, it also makes the following points:

• Insurance Europe backs the ISSB’s decision not to require mandatory disclosure of financed emissions from derivative contracts, due to the absence of widely accepted calculation methodologies.
• On the use of industry classification systems, insurers support the option to use alternatives to the Global Industry Classification Standard (GICS). This flexibility avoids unnecessary legal and cost burdens and is especially important for multinational entities already governed by other frameworks.
• Insurers welcome the proposed jurisdictional reliefs, which allow companies operating across several regulatory environments to use alternative methodologies or global warming potential (GWP) values where required by local laws. Insurance Europe emphasises that while this flexibility is essential for operational feasibility, the IPCC’s standards must remain the global reference to preserve consistency and comparability.
  
  

European insurers urge the ISSB to implement the proposed amendments as swiftly as possible, especially as many (re)insurers are already working to align with IFRS S2.