Major U.S. Insurers Make Progress on Climate Disclosures, but Significant Gaps Remain

BOSTON, June 4, 2025—A new report released today 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.  

While the report documents improvements in climate risk identification and governance structures, it emphasizes that disclosure alone is insufficient. 

"The continuing gaps in the metrics and targets area represent an urgent concern," said Dr. Jaclyn de Medicci Bruneau, Director of Insurance at Ceres Accelerator for Sustainable Capital Markets and lead author of the report. "Without measurable targets and metrics, stakeholders cannot effectively assess insurers' progress or hold companies accountable for their climate risk goals. This finding is particularly significant given 2024's unprecedented weather events, which included 27 billion-dollar disasters totaling $182.7 billion in damages." 

Key findings from the report: 

• 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. 

(Editor’s note: These and the other measurements only reflect that reporting in these areas is included. It does not reflect that all of them are comprehensive in nature.) 

Today 85% of U.S. insurers have disclosed climate risk, more than the rest of the world combined. 

"With climate impacts intensifying at an alarming rate, reporting alone cannot be the end goal," Dr. de Medicci Bruneau noted. "Strong disclosure practices, particularly in the critically underreported metrics and targets pillars, must serve as the foundation for strategic transformation and actionable transition plans." 

The report comes as the insurance industry confronts unprecedented challenges from increasingly extreme weather events. The global protection gap – the difference between economic losses and insured coverage – is projected to increase by 5% to $1.86 trillion in 2025. In the U.S., an estimated 8% of homeowners now forgo insurance entirely due to affordability concerns, leaving $1.6 trillion in unprotected assets.   

The report also includes best practices from insurers demonstrating leadership, and provides recommendations for companies and regulators, such as: 

• Establishing comprehensive metrics frameworks that address both underwriting and investment portfolios 

• Setting science-based targets with specific interim milestones and clear baseline measurements 

• Investing in tools to measure greenhouse gas emissions across all scopes 

• Expanding industry collaboration on standardized methodologies and frameworks 

• Progressing from TCFD disclosures to actionable climate transition plans 

“Insurers are the risk managers of the economy and uniquely positioned to mitigate the financial impacts of a changing climate,” said Laura Zizzo, Founder and Chief Strategy Officer at Manifest Climate. “To lead effectively, they must set the standard with clear, decision-useful disclosures—and demand the same from the companies they underwrite and invest in. AI-powered analysis helps turn complex public data into actionable insights, and we’re proud to support Ceres in advancing transparency and accountability across the sector.” 

This is Ceres' third annual report analyzing the insurance industry's TCFD disclosures, building on previous analyses released in 2023 and 2024.    

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About Ceres Accelerator for Sustainable Capital Markets  

The Ceres Accelerator for Sustainable Capital Markets is a center within Ceres that aims to improve the practices and policies that govern capital markets by engaging federal and state regulators, financial institutions, investors, and corporate boards to act on climate risk as a systemic financial risk. For more information, visit ceres.org/accelerator. 

About Manifest Climate  

Manifest Climate is the leading Climate Intelligence Software that provides decision-makers with climate-related insights and recommendations to inform decisions, seize opportunities and mitigate risk. Manifest Climate uses industry-leading AI models to create comparability from qualitative climate information faster, more accurately and more consistently than humans. Issuers, service providers and financial institutions choose Manifest Climate for ease of use, in-house climate expertise, and depth of qualitative climate data. With Manifest Climate, teams reduce time spent on manual research by 99%, improving precision and consistency as a result. Learn more at www.manifestclimate.com.