Policy Paper

Scope 3 Emissions for Property/Casualty Insurers

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Publish Date:

10/7/2025

Category:

Policy & Research

Topics:

Climate Risk, Financial Reporting, Public Policy

In this policy paper, the Climate Related Financial Disclosures work group has detailed some of the most difficult challenges involved in financial reporting of Scope 3 Emissions for United States insurance companies.  While Scope 1 and 2 Emissions originate in the operations of the reporting company, Scope 3 Emissions originate in the operations of companies upstream and downstream from the reporting company.  While recognizing the stated benefits from proponents of Scope 3 reporting, the paper documents issues of scope, clarity and data availability as problematic for those tasked with this reporting.