Coverage requirements for insurers


as in insurer, our assumption is that emissions from insurance as well as from our internal asset managers (subsidiaries) are not in scope of the scope 3 requirements. Is this assumption correct as of 2022?

And if yes, will this requirement change in the future?

And if no, what is in scope and where is this specified? We only found reference for banks that it’s voluntary for them as of today to include their AM emissions.


Hi Thomas - thanks for getting in touch. Insurance is currently out of scope so would not have to be covered by targets. However, we are starting the work to develop methods for insurance asset classes so these will be incorporated into the framework once they are completed. The SBTi will be expanding the framework over time with the ultimate vision of covering all relevant asset classes, including new methods for sovereign debt, and capital market activities (securities underwriting).

Regarding internal asset managers - these would be considered in scope and have to be covered by targets. For asset owners, all asset management activities, but internal and external would be within scope. Hope this helps clarify your questions, but please let us know if you would like additional clarification.

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Hi there - similar to Thomas, we’re a large global insurer and have also made the same assumption. That is, that emissions from investments associated with our general account are in scope but emissions from third-party asset management activities are out of scope for target setting at this time. It sounds like this is incorrect - that we also need to include third-party asset management activities in order to receive validation?

Can you help point me in the direction of the section of the guidance that outlines these requirements (for both internal and external asset management activities as being “in scope”)? Thank you!

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Thanks for replying Eion. This expansion of scope is noted but I would assume it cannot automatically apply to existing commitments and targets. It would apply once a company is submitting a new target, right?

And where in the documentation can I find that 3rd party assets managed are in scope for insurance companies?

Thanks for the follow up. As we take an asset class approach, it is expected that FIs include all investment activities that are in-scope. The coverage criteria of page 53 of the guidance highlights that all relevant investment and lending activities should be covered. For asset owners/asset managers this relates to all funds managed under discretionary mandates i.e. FIs must cover all investment activities in mandatory asset classes (e.g. listed equity, bonds) where the FI has the ability to make the final investment decision. Advisory mandates or other strategies where the FI does not have the ability to influence/control the investment are out-of-scope.

The SBTi has always mandated that all activities of a parent company would be taken into account, this being applied to both companies and financial institutions. The guidance only highlights the current exception to this rule, which is for the case of banks. This criteria is also under review and we will expect the AM of banks to be included with future updates to the framework.

As this criteria is currently in use, it is applied to all FIs submitting targets.

Dear Eoin,
this is very clear, thank you!