Scope
Are insurers in scope?
Like banks, insurers are named directly in the existing law.
Section 414CB of the Companies Act 2006 applies to insurance companies, so any large insurer with more than 500 employees and turnover above £500 million or a balance sheet above £500 million already makes climate-related financial disclosures Companies Act 2006 s.414CB.
Listed insurers additionally fall within the FCA's proposed UK SRS S2 regime under CP26/5, which covers UK Listing Rules categories 6, 14, 15, 16 and 22 from financial years beginning on or after 1 January 2027 FCA CP26/5.
The UK SRS standards themselves were published by the Department for Business and Trade on 25 February 2026 DBT.
Footprint one
The investment book: financed emissions
An insurer holds large investment portfolios to back its liabilities, and those holdings carry financed emissions exactly as a bank's do.
IFRS S2 requires Scope 1, 2 and 3 emissions on the GHG Protocol Corporate StandardGHG Protocol, and the financed share is calculated using the PCAF financed-emissions methodology across asset classes such as listed equity and corporate bonds PCAF Standard, Part A.
For a life insurer with a large general account, this investment-side footprint usually dominates; for a general insurer running shorter-tail books, it is smaller but still the primary Scope 3 figure IFRS S2.
The mechanics are the same as the banking case, covered on the financed emissions page.
Footprint two
The underwriting book: insurance-associated emissions
The footprint unique to insurers is on the liability side.
The emissions of the activities an insurer underwrites — insurance-associated emissions — are addressed by a dedicated PCAF methodology built specifically for the sectorPCAF Standard, Part C.
The IFRS S2 industry-based guidance for the insurance activity points reporters toward disclosing this underwriting dimension alongside the investment oneIFRS S2 industry-based guidance.
It is the newest and least mature of the financial-sector measurement methods, which is precisely why insurers should engage with it early rather than treat it as a later add-onPCAF Standard, Part C.
Timing
The timeline and what to build now
The proposed first UK SRS S2 reporting year for listed insurers is the financial year beginning 1 January 2027 FCA CP26/5.
Both portfolio footprints sit in Scope 3 and so benefit from one year of transitional relief, becoming comply-or-explain a year later FCA CP26/5.
Because the underwriting methodology is still maturing, the relief is best read as time to build, not time to defer.
Assurance is not yet mandatory, but an insurer that assures must disclose the provider, level and standard — in the UK, ISSA (UK) 5000FRC, ISSA (UK) 5000.
The standards underneath are on the IFRS S1/S2 hub.