Climate change readiness for insurers: now is the time to up the tempo
With surprisingly little fanfare, SS4/25 has replaced SS3/19. It applies to all insurers and Lloyd's syndicates, and compliance is expected now.
With surprisingly little fanfare considering the implications for insurers, the PRA's Supervisory Statement SS4/25, Enhancing banks' and insurers' approaches to managing climate-related risks, is here and SS3/19 is no more.
What it means
- It applies to all insurers and Lloyd's syndicates, regardless of size, although not to branches.
- Firms should review where they stand against the expectations and have action plans that are both credible and ambitious.
- Compliance is expected now, with effect from 3 December 2025, and supervisors will ask for evidence of progress by 3 June 2026.
The new standard largely follows the six areas for insurers set out in the consultation, CP10/25: governance, risk management, climate scenario analysis, data, disclosures and issues for insurers.
Importantly, it has taken on board feedback and recommendations made by Alex and other members of the Institute and Faculty of Actuaries Climate Change Working Party, notably that firms should recognise the complex issues surrounding litigation risk.
How prepared are you?
Two priority activities where Marcuson Consulting can help P&C insurers:
- Gap analysis and maturity self-assessment: preparation, training and review.
- Climate scenario analysis: deploying a set of climate scenarios to assess the impact on your business.
Talk to us about where you are and what comes next.
