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:
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.