Notice – Discussion Paper – Disclosure of Climate Change Risks for Commercial Insurers (2023-09-27)

Summary

This notice announces a Discussion Paper (DP) issued by the BMA seeking industry feedback on proposed public disclosure requirements for climate change risk for commercial insurers. It is a consultative document, not a binding rule, and previews a future phased-in disclosure regime aligned with the TCFD framework.

• Purpose: Solicits feedback on how insurers should publicly disclose climate risk exposure, mitigation and monitoring activities on an annual basis.
• Framework alignment: Proposals aim to align with the Task Force on Climate-Related Disclosures (TCFD) four pillars: governance, strategy, risk management, and metrics and targets.
• Context: Builds on prior BMA climate work including climate change surveys, amendments to the Insurance Code of Conduct, and the Guidance Note on Management of Climate Risk for Commercial Insurers.
• Next steps: After reviewing feedback, the Authority intends to issue a consultation paper proposing climate risk disclosures for all commercial insurers using a phased-in approach.

Stakeholders are invited to respond to all 18 questions in the DP using the required Appendix C Excel spreadsheet format, submitted by email before the response deadline.

Key obligations

• Stakeholders wishing to comment must submit responses to all 18 DP questions using the Appendix C Excel spreadsheet format
• Responses must be emailed to climaterisk@bma.bm before the response deadline, with the subject line including the company name followed by 'Discussion Paper – Disclosure of Climate Change'

Applies to

commercial insurers

Deadlines

• 15 December 2023: Response deadline for feedback on the Discussion Paper on Disclosure of Climate Change Risks for Commercial Insurers