Dear John,
A new report released yesterday reveals that while major U.S. insurance companies are making progress in disclosing their climate-related risks and strategies, significant gaps remain, particularly in the critically important metrics and targets area.
“The 2025 Progress Report: Climate Risk Reporting in the U.S. Insurance Sector" analyzes the disclosure reports from 526 insurance groups, which total more than 1,723
individual companies, submitted to the National Association of Insurance Commissioners' (NAIC) Climate Risk Disclosure Survey for reporting year 2023.
The analysis, conducted with AI-powered sustainability intelligence provider Manifest Climate, evaluated insurance company responses against the Task Force on Climate-related Financial Disclosures (TCFD) framework. | | | | | | Download the full report and review its key findings, including: - 99% of insurers reported on risk management processes, 97% on strategy, 87% on governance, but only 29% disclosed metrics and targets related to climate risks.
- Just 28% of insurers provided disclosures across all four pillars of the TCFD framework (governance, strategy, risk management, metrics and targets).
- A year-over-year comparison showed improvement in risk management integration, identifying climate risks and opportunities, and reporting greenhouse gas emissions.
- However, the metrics and targets pillar continues to lag significantly, with virtually no improvement from previous years despite growing climate impacts.
- The increasing adoption of climate scenario analysis by insurers is encouraging, with 148 groups conducting this forward-looking assessment in 2023, up from 116 in 2022.
While the report documents improvements in climate risk identification and governance structures, it emphasizes that disclosure alone is insufficient. We hope that this analysis will encourage continual improvement in the comprehensiveness and usefulness of climate-related disclosures in future years. | | |
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Steven Rothstein
Managing Director,
Ceres Accelerator for Sustainable Capital Market Systems | | | | |
Ceres is a nonprofit advocacy organization working to accelerate the transition to a cleaner, more just, and resilient world.    
| | | | | | Ceres is proud to receive these accolades as a reflection of our effectiveness, integrity and impact.
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