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PCAF Part C · Insurance-associated emissions

PCAF Part C: insurance-associated emissions

PCAF Part C measures insurance-associated emissions: the emissions of the risks an insurer or reinsurer underwrites.

It attributes by the share of risk transferred, not by capital deployed, and its figures are never added to financed emissions.

The Second Edition, published in December 2025, grows the Standard from two segments to four.

Checked against 16 sources fromPCAFGHG ProtocolIFRS FoundationIFRS Foundation (hosted by the AASB)Department for Business and TradeFinancial Conduct Authorityand 1 moreSee the sources

The Second Edition

Four segments, two of them new

PCAF published the first version of Part C in November 2022, covering commercial lines and personal motor insurance.

The Second Edition, dated December 2025, “was developed to expand the Standard’s scope to include methodologies for project insurance and treaty reinsurance”.

PCAF’s launch notice of 2 December 2025 lists those two as new insurance-associated emissions methods, released alongside Part A’s Third Edition.

Treaty reinsurance takes the boundary along the reinsurance chain, so the Standard now has to deal with a risk that has been passed on more than once.

PCAF’s standard page lists Part C at its 2nd edition, beside Part A’s 3rd edition and Part B’s December 2023 version.

The three Parts together are explained on the PCAF Standard.

How Part C grew

  1. Nov 2022
    First version

    Commercial lines and personal motor.

  2. Dec 2025
    Second Edition

    Adds project insurance and treaty reinsurance.

Source: PCAF Part C executive summary, December 2025

The principle

“Follow the risk”, not the capital

Part A and Part B attribute emissions by capital: the money lent, invested or raised, divided by the counterparty’s value.

Part C works on a “follow the risk” basis instead, attributing by the portion of risk transferred to the insurer or reinsurer.

An insurer that takes on a share of a policyholder’s risk takes the same kind of share of that policyholder’s emissions.

A reinsurer then takes a share of what the insurer passed on, which is why the Standard needs rules for the reinsurance chain.

The capital-based methods are on PCAF Part A and PCAF Part B.

Separate, always

PCAF Part C says insurance-associated emissions “shall be reported separately” and “shall not be aggregated with financed emissions”.

An insurer’s underwriting figure and its investment-portfolio figure are two numbers, not one total.

The boundary

Category 15, but not financed

Underwriting is a different relationship from lending or investing: there is no loan, no bond and no stake.

Sources: IFRS S2 amendments, ¶29A and BC121D; PCAF Part C, Second Edition. Our summary.
An insurer’s activityPCAF PartCategory 15?Financed emissions under IFRS S2 and UK SRS S2?
Investing premiums in equities, bonds and loansPart AYesYes
Underwriting commercial lines, personal motor, project insurancePart CYesNo — ¶29A lets it be left out
Reinsuring another insurer through a treatyPart CYesNo — ¶29A lets it be left out

The GHG Protocol’s Scope 3 Standard puts investments in Category 15, and insurance-associated emissions are treated as Category 15 emissions too.

IFRS S2 as amended in December 2025 defines financed emissions by reference to loans and investments, so underwriting emissions fall outside that definition.

The Basis for Conclusions to the ISSB’s amendments names “insurance-associated emissions that are associated with insurance and reinsurance underwriting activities” as another type of Category 15 emissions.

It gives the example of an entity that “might apply the relief to exclude emissions associated with its insurance underwriting activities”.

The same document restates the ISSB’s original position: “IFRS S2 does not require disclosure of the ‘associated emissions’ of underwriting portfolios in the insurance and reinsurance industries.”

That position dates back to the June 2023 Basis for Conclusions on IFRS S2.

Data quality

A 1–5 scale — in this edition

The Second Edition’s commercial lines score table, Table 5.2-2, runs from score 1, the highest data quality, to score 5, the lowest.

The first version of November 2022 used a four-level scale at the same table number.

So “PCAF Table 5.2-2” without an edition is ambiguous between a 1–5 and a 1–4 scale, and a citation should always name the Second Edition.

The same 1-is-best convention runs through Part A; it is covered on PCAF data quality scores.

In the UK

What UK insurers are actually asked

UK SRS S2 lists insurance among the three activities with financed emissions duties, in ¶B59 and ¶¶B63–B63A.

Those duties attach to the insurer’s loans and investments, measured on a Part A basis if the insurer uses PCAF, not to its underwriting.

UK SRS S2 was published by the Department for Business and Trade on 25 February 2026 and is a voluntary standard in itself.

The FCA’s final rules in PS26/19, following its CP26/5 consultation, require listed companies in scope to report against it on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

Separately, life insurers that are in-scope asset owners already report emissions metrics in TCFD product reports under FCA ESG 2.3.9R, a rule that does not name PCAF.

The PRA’s expectations on climate risk management are in Supervisory Statement SS5/25, which commenced on 3 December 2025 and replaced SS3/19 in its entirety.

Policy Statement PS25/25 says the same, and the Bank serves the SS5/25 PDF under a file name that reads SS4/25.

SS5/25 sets expectations; it is not a disclosure rule, and it does not prescribe PCAF.

How the pieces fit for an insurer is on UK SRS for insurers; nothing here is financial, investment or legal advice.

Frequently asked

PCAF Part C — frequently asked

What is PCAF Part C?

Part C is the Insurance-Associated Emissions part of the PCAF Standard. It sets out how an insurer or reinsurer measures the greenhouse gas emissions associated with the risks it underwrites. The current version is the Second Edition, published in December 2025; the first version was published in November 2022.

What are insurance-associated emissions?

They are the emissions of policyholders attributed to the insurer or reinsurer that underwrites their risk. PCAF attributes them by the share of risk transferred to the (re)insurer — “follow the risk” — rather than by capital deployed, which is how loans and investments are measured.

What does the Second Edition cover?

Four segments. Commercial lines and personal motor were in the first version of November 2022; the Second Edition of December 2025 added project insurance and treaty reinsurance.

Are insurance-associated emissions financed emissions?

No. They are Scope 3 Category 15 emissions, but not financed emissions, which IFRS S2 defines by reference to loans and investments. PCAF Part C says insurance-associated emissions shall be reported separately and shall not be aggregated with financed emissions.

Does IFRS S2 or UK SRS S2 require insurance-associated emissions?

No. The ISSB’s own text says IFRS S2 does not require disclosure of the “associated emissions” of underwriting portfolios in the insurance and reinsurance industries, and paragraph 29A lets an entity limit Category 15 to financed emissions. UK SRS S2 carries the same paragraph. An insurer’s investment portfolio, by contrast, produces financed emissions that UK SRS S2 does ask about.

What is the PCAF data quality score for insurance?

In the Second Edition, the commercial lines score table runs from 1, the highest data quality, to 5, the lowest. The first version of November 2022 used a four-level scale at the same table number, so a citation of Table 5.2-2 needs its edition.

Did the PRA replace SS3/19?

Yes. PRA Supervisory Statement SS5/25 commenced on 3 December 2025 and replaced SS3/19 in its entirety. It sets supervisory expectations on managing climate-related risks for banks and insurers; it is not a disclosure rule and does not prescribe PCAF.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

  1. PCAF
    Part C: Insurance-Associated Emissions, Second Edition (December 2025)

    "Follow the risk"; reported separately, never aggregated with financed emissions; Table 5.2-2 on a 1–5 scale.

  2. PCAF
    Part C, Second Edition — executive summary (December 2025)

    First version November 2022; project insurance and treaty reinsurance added.

  3. PCAF
    PCAF launches updated GHG accounting standard (2 December 2025)

    Two new insurance-associated methods: treaty reinsurance and project insurance.

  4. PCAF
    The Global GHG Accounting and Reporting Standard — standard page

    Part C listed at its 2nd edition (2025).

  5. GHG Protocol
    Corporate Value Chain (Scope 3) Standard — Category 15

    The category insurance-associated emissions sit in.

  6. IFRS Foundation
    Amendments to Greenhouse Gas Emissions Disclosures (IFRS S2) — ¶29A, BC121D, BC121I

    Underwriting emissions as a Category 15 type an entity may exclude.

  7. IFRS Foundation
    ISSB issues targeted amendments to IFRS S2

    December 2025 announcement.

  8. IFRS Foundation (hosted by the AASB)
    IFRS S2 Basis for Conclusions, June 2023

    The original Basis for Conclusions on associated emissions of underwriting portfolios.

  9. Department for Business and Trade
    UK SRS S2, ¶¶29A, B59, B63–B63A

    Insurance is one of the three activities with financed emissions duties.

  10. Department for Business and Trade
    UK SRS S1 and UK SRS S2 — publication page

    Published 25 February 2026 for voluntary use.

  11. Financial Conduct Authority
    PS26/19: Aligning listed issuers’ sustainability disclosures with international standards (30 September 2026)

    The final rules: listed companies in scope report against UK SRS on a comply-or-explain basis for accounting periods starting on or after 1 January 2027, with a one-year Scope 3 relief.

  12. Financial Conduct Authority
    CP26/5 — Aligning listed issuers’ sustainability disclosures with international standards

    The consultation PS26/19 finalises; it had proposed mandatory UK SRS S2.

  13. Financial Conduct Authority
    FCA Handbook, ESG 2.3.9R

    Product-level emissions metrics for in-scope asset owners, including life insurers.

  14. Bank of England
    PRA Supervisory Statement SS5/25 — landing page

    SS5/25 §3.1: commenced 3 December 2025 and replaced SS3/19 in its entirety.

  15. Bank of England
    SS5/25 — PDF (served under an SS4/25 file name)

    The Bank labels the download "Amended from SS4/25"; cite the reference number, not the file name.

  16. Bank of England
    PRA Policy Statement PS25/25

    ¶1.20: the final policy replaces SS3/19 in its entirety.

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