CSRD and Solvency II Readiness for Insurers

In brief

• The reporting framework is fixed in law. Omnibus I (Directive (EU) 2026/470) set the scope. The revised ESRS (Delegated Regulation (EU) 2026/1563) set the content.
• Most large insurers remain in scope. Mandatory reporting applies above 1,000 employees and €450m net turnover, tested at entity or group level.
• The prudential deadline comes first. From 30 January 2027 the amended Solvency II Directive requires a sustainability risk plan and, where exposure is material, climate change scenario analysis in the ORSA. The Commission has deprioritised EIOPA’s technical standards, so there will be no detailed rulebook before the deadline. The obligation applies regardless.
• FY2026 is a choice year. Insurers already reporting may use the 2023 ESRS, the 2023 ESRS with selected reliefs, or the revised ESRS early. Make the choice, and minute it, before 31 December.
• Underwriting is where insurers differ from every other reporter. Insurance-associated emissions, the Taxonomy underwriting KPI and the recalibrated natural catastrophe charges all depend on line-of-business and location data that few insurers yet hold in one place.

1. Where the rules stand

The instruments that now govern an insurer’s sustainability reporting and risk management, with their status on 4 November 2026.

One implication is easy to miss. With the CSDDD transition-plan obligation gone, the binding planning instrument for EU insurers is the Solvency II sustainability risk plan. It must exist by 30 January 2027, before the first FY2027 ESRS report is drafted.

2. Where does your company sit?

Find your position in the first column. The right-hand column is the step that should already be under way.

3. What the revised ESRS change for an insurer

• Materiality can be assessed top-down. Insurers may conclude at topic or sub-topic level where materiality is evident and refresh the assessment only on significant change. The Solvency II plan needs its own sustainability materiality assessment; build both from one evidence base so they cannot contradict each other.
• Investment emissions stay in; underwriting emissions need a documented position. Scope 3 category 15 remains part of E1 for investments. For underwriting, PCAF’s insurance-associated emissions standard (second edition, December 2025) is the measurement reference, while IFRS S2 now allows insurers to leave these emissions out. Under ESRS, whether to include them is a materiality and methodology decision. Record it, and the reasons, either way.
• Intensity targets get relief. The new exemption from disclosing absolute values behind intensity-based financed-emissions targets is relevant to insurers’ investment portfolios. Confirm its application with your auditor. Separately, the GHG boundary becomes a choice of financial control, operational control or equity share.
• Managed investments may fall outside the assessment. Investments managed under a fiduciary duty for clients, where the undertaking does not retain the risks and rewards of ownership, are exempt. This clearly helps asset management subsidiaries. For unit-linked business, where policyholders bear the investment risk, the position is debated; document your interpretation.
• Anticipated financial effects are deferred, with one exception. Insurers reporting since FY2024–26 may omit all such information before FY2028 and quantitative information before FY2030. The core E1 datapoints on assets at material physical and transition risk are not deferred.
• Value-chain requests have a ceiling. You cannot require more than the voluntary standard from counterparties with 1,000 employees or fewer. GHG emissions data are outside the cap, so requests to commercial policyholders and investees for Scope 1–3 data remain possible.

4. Three decisions to take before 30 January 2027

Decision 1 — Your FY2026 reporting route

Artamis view: for most Wave 1 insurers, Route B or C costs less over two reporting cycles than Route A. Whichever route you take, state it explicitly in the report.

Decision 2 — Finish the sustainability risk plan without waiting for the RTS

Work from the amended directive, EIOPA’s December 2024 draft RTS and your national supervisor’s guidance. Integrate the plan into the ORSA rather than writing a stand-alone document. Cover underwriting and investments, short-, medium- and long-term horizons, and the actions and metrics you will use to manage the risks you identify.

Decision 3 — Fix the underwriting data scope

Decide which lines of business will carry insurance-associated emissions measurement, which premiums would sit in a narrower Adaptation Underwriting KPI, and where exposure data by location is good enough for natural catastrophe and physical-risk analysis. This is the long-lead item.

5. One data build, four outputs

An insurer’s sustainability data serves four regimes with overlapping inputs. Build it once, at policy and holding level, to an assurance standard.

6. Five pitfalls we see

• Waiting for the technical standards. They have been deprioritised. The 30 January 2027 obligation stands on the directive alone.
• Two materiality assessments that disagree. An ESRS assessment and a Solvency II assessment that reach different conclusions on climate or nature will be read side by side.
• Treating underwriting emissions as all or nothing. Measure where data supports it, disclose the method and coverage, and extend line by line.
• Assuming the Wave 1 exemption before your member state grants it. The directive permits it; only national law delivers it.
• Scenarios that stay in the ORSA. Climate and natural catastrophe analysis that never reaches pricing, reinsurance purchasing or the CSRD report is the gap supervisors are now looking for.

7. Ten questions for your next risk or sustainability committee

1. Which FY2026 ESRS route have we chosen, and is the rationale minuted?
2. Will the board approve our sustainability risk plan before 30 January 2027?
3. Does our ORSA include climate change scenario analysis, and do the scenarios match our ESRS E1 resilience analysis?
4. Do our ESRS and Solvency II materiality assessments rest on one evidence base?
5. Which lines of business have measured insurance-associated emissions, and at what data quality?
6. How will the recalibrated natural catastrophe factors change our SCR, and does pricing reflect them?
7. What share of the investment portfolio has reported, rather than estimated, investee emissions?
8. Is our Taxonomy underwriting KPI ready for a narrower, adaptation-only definition?
9. For unit-linked business, have we documented whether the managed-investments exemption applies?
10. Which nature-related dependencies are material in underwriting and investments, and how would we evidence that to the supervisor?

8. What to watch over the next twelve months

Key sources

Directive (EU) 2026/470 (Omnibus I); Delegated Regulations (EU) 2026/1563 (revised ESRS) and 2026/1560 (voluntary standard); Directive (EU) 2025/2 and Delegated Regulation (EU) 2026/269 (Solvency II).

EIOPA, Final Advice on (re)insurers’ Taxonomy disclosures, 30 October 2026; Q&A 3630; Supervisory priorities 2026. PCAF Insurance-Associated Emissions standard, 2nd ed.; IFRS S2 amendments; SFDR 2.0 proposal; FINMA Circular 2026/01.

General information on the regulatory position at the date shown; not legal advice. Several instruments are still under negotiation and national practice varies; confirm your position with counsel.