Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The American Property Casualty Insurance Association (APCIA) appears to have had generally negative engagement on climate-related finance policy, opposing climate disclosure regulation efforts at both the federal and state levels and suggesting that climate-related insurance risk regulation is unnecessary. APCIA has also engaged on several state-level “anti-ESG” bills, with unclear or unsupportive positions.
Top-Line Messaging on Climate-Related Finance Policy: APCIA suggested that concerns regarding the financial system and climate-related risk are “largely anecdotal” in 2022 comments to the Financial Stability Board. In May 2023 comments to the International Association of Insurance Supervisors (IAIS), APCIA appeared to suggest that concerns regarding the insurance sector and climate-related risk are overblown.
Position on Regulated Corporate Climate Disclosure: APCIA does not appear to support regulated corporate climate disclosure for insurers. In a 2023 white paper, APCIA asserted that “massive, duplicative” climate reporting requirements were adding cost pressures for insurance companies. APCIA opposed Scope 3 disclosure requirements in response to an IAIS consultation in 2024, however APCIA did support several aspects of the proposal including the need for proportionality.
APCIA has also engaged negatively on US state-level disclosure bills. APCIA has consistently opposed California climate disclosure bills in 2022, 2023, and 2024 and took a mixed position in a 2025 consultation response–supporting the alignment of disclosure frameworks with the GHG Protocol while emphasizing the costs of compliance with the rule. In June 2025, APCIA also opposed New York emissions disclosure legislation, describing it as "burdensome" and specifically objecting to the proposed Scope 3 disclosure requirements.
Position on Climate Standards, Labels, and Benchmarks and ESG Ratings: APCIA, in a 2024 IAIS consultation response, opposed the need for greenwashing regulation for insurance products, instead emphasizing the role of efforts outside the insurance industry to pursue resilience and combat catastrophe risk.
Position on Incorporating Climate Factors Into Investor Duties: APCIA has engaged on “anti-ESG” legislation at the state and federal level. According to a 2023 Florida lobbying disclosure, APCIA engaged on HB 3, legislation to prohibit the use of ESG factors in investment decision making. Details of APCIA’s engagement are unclear. In 2023 APCIA took a “neutral” position on Kansas HB 2436 and RS 1490, bills that would prohibit the use of ESG factors in state investment decisions. In 2024, APCIA opposed Arizona SB 1014 which would ban financial institutions from “discriminating” based on ESG criteria. According to a Q1 2024 federal lobbying report, APCIA also engaged on several bills that were introduced a part of the House “anti-ESG” month, including legislation that would limit the SEC’s authority over the shareholder proposal and proxy voting process and allow companies to exclude ESG-related proposals from the ballot.
Position on Incorporating Climate Factors Into Prudential Regulation/Risk Management: APCIA does not appear to support policies to incorporate climate factors into risk management and prudential regulation. In 2023 APCIA opposed a Connecticut bill that would impose a surcharge on insurers that underwrite fossil fuel companies. APCIA has consistently opposed the Federal Insurance Office (FIO)’s proposed climate data collection from insurers, endorsing federal legislation that would block the FIO’s efforts to collect this data in 2023, 2024 and again in 2025.
APCIA has also engaged with the IAIS’ work to develop global standards for climate-related insurance risk management. APCIA has consistently cautioned the IAIS against "elevating" climate risk above other risks and advocated for increased flexibility across its May 2023, February 2024, June 2024 and October 2024 responses.
Alternatively, APCIA has opposed efforts to prohibit the use of climate factors in risk management and prudential regulation, so-called “anti-ESG” bills. In February 2023 testimony, APCIA opposed a South Dakota bill that sought to ban the use of ESG factors in insurers’ risk management and underwriting activities. Also in 2023, APCIA opposed a Texas bill that sought to prohibit the use of ESG factors in insurers’ underwriting practices, telling Bloomberg that it would introduce “unnecessary and potentially expensive complexities into the insurance marketplace.” In 2023, APCIA opposed a Kansas bill that would restrict the use of ESG factors in insurers’ risk management, and “reluctantly” opposed a North Dakota bill that would limit insurers’ consideration of ESG factors in ratemaking decisions.
Position on Energy, Industry, and Land Transition: According to a Q1 2024 federal lobbying report APCIA has engaged on implementation of the Inflation Reduction Act, but its position on the legislation’s climate provisions is unclear. In May 2025 APCIA endorsed the House budget reconciliation bill (One Big Beautiful Bill Act) which is set to repeal many of the Inflation Reduction Act's climate incentives and facilitate the buildout of fossil fuel infrastructure.