Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The Association of British Insurers (ABI) has communicated high-level support for sustainable finance policy, with particularly high engagement on UK sustainable finance policy.
Top-line Messaging on Climate-Related Financial Policy: In its 2022 and 2023 Climate Change Roadmaps ABI has advocated for the role of the insurance and long-term savings sector in keeping temperature rise within 1.5C and achieving net-zero by 2050, and delivering the UK Government’s Net Zero Strategy.. It has also supported UK’s efforts on sustainable finance policy through its Greening Finance Roadmap in 2022.
Position on Regulated Corporate Climate Disclosure: ABI appears to be supportive of regulated corporate climate disclosure. In a joint letter to the UK government with large companies in 2021, ABI advocated for the disclosure of net-zero transition plans, and it also supported the work of the UK Transition Plan Taskforce in 2022 written evidence to Parliament and in feedback to the UK Government on its Update to the Green Finance Strategy in 2022. In its 2022 Climate Change Roadmap, ABI supported mandatory implementation of the TCFD in the UK. It further advocated for more ambitious disclosures, such as mandatory scope 3 and qualitative scenario narratives for large companies in a 2021 consultation response to the Business, Energy & Industrial Strategy (BEIS) department.
Position on Taxonomies: In its 2022 Climate Change Roadmap and its 2023 A Guide to Action on Nature, ABI supported the UK Green Taxonomy. In feedback to the UK’s Update to the Green Finance Strategy in 2022, it further supported a UK Green Taxonomy based on “the most recent scientific evidence”.
Position on the Incorporation of Climate Factors into Investor Duties: ABI has stated concerns around disclosure on integrating ESG into investor duties and integration of climate into risk management. In response to the FCA's consultation on Sustainability Disclosure Requirements (SDR) in 2021,
Position on the Incorporation of Climate Factors into Risk Management: ABI highlighted issues of data availability and suggested a sequencing of information across the market. In response to the FCA in 2022, it also cautioned against a default model for pension funds that accounts for climate risks. In its 2022-2023 Climate Change Roadmap, ABI broadly supported the integration of climate factors into investor duties. In the same Roadmap, it supported ensuring that climate risks strategies are embedded in the industry following Bank of England's 2021/22 Climate Biennial Exploratory Scenario as well as advancing capabilities of the industry for managing climate-related risks. However, on its corporate website, ABI stated an unclear position regarding engagement with the Bank of England on the Climate Biennial Exploratory Scenario, stating that the ABI’s working group ‘helped to ensure a more proportionate approach.’
Position on Real Economy Climate Policy: ABI actively supported GHG emissions targets for the phase-out of petrol and diesel cars by 2030 and 2035 in the UK in written evidence to the House of Lords in 2021. It has also supported legislation to increase energy efficiency in the UK housing stock in written evidence to the Environmental Audit Committee in 2022.