Para 6. Governance: board oversight and management’s role
An entity must identify the body or individual responsible for climate-related oversight, and disclose how their mandate, skills, information cadence, transaction-decision integration, and target oversight reflect that responsibility. Para 6(b) covers the management-level position or committee that handles day-to-day climate management, and how it integrates with other internal controls.
Standard text (verbatim, IFRS S2 Para 6)
To achieve this objective, an entity shall disclose information about:
(a) the governance body(s) (which can include a board, committee or equivalent body charged with governance) or individual(s) responsible for oversight of climate-related risks and opportunities. Specifically, the entity shall identify that body(s) or individual(s) and disclose information about:
(i) how responsibilities for climate-related risks and opportunities are reflected in the terms of reference, mandates, role descriptions and other related policies applicable to that body(s) or individual(s);
(ii) how the body(s) or individual(s) determines whether appropriate skills and competencies are available or will be developed to oversee strategies designed to respond to climate-related risks and opportunities;
(iii) how and how often the body(s) or individual(s) is informed about climate-related risks and opportunities;
(iv) how the body(s) or individual(s) takes into account climate-related risks and opportunities when overseeing the entity’s strategy, its decisions on major transactions and its risk management processes and related policies, including whether the body(s) or individual(s) has considered trade-offs associated with those risks and opportunities;
(v) how the body(s) or individual(s) oversees the setting of targets related to climate-related risks and opportunities, and monitors progress towards those targets (see paragraphs 33-36), including whether and how related performance metrics are included in remuneration policies (see paragraph 29(g)).
(b) management’s role in the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities, including information about:
(i) whether the role is delegated to a specific management-level position or management-level committee and how oversight is exercised over that position or committee;
(ii) whether management uses controls and procedures to support the oversight of climate-related risks and opportunities and, if so, how these controls and procedures are integrated with other internal functions.
The Board of Directors holds ultimate accountability for climate-related risks and opportunities. The Sustainability Committee of the Board oversees the climate strategy; full Board approval is required for the annual Climate Action Plan, the natural-perils reinsurance program, climate-related capital deployment in the budget, and any climate measures in executive incentive plans. The Risk Committee owns the Group Risk Appetite Statement (RAS), which from FY26 includes a qualitative climate statement consistent with APRA Prudential Standard CPS 220. [IFRS S2.6(a)(i), (iv); CPS 220]
Information cadence (Para 6(a)(iii)). Twice-yearly sustainability updates to the full Board, an annual Strategic Risk Profile review (climate is a standing strategic risk), and ad-hoc updates after material peril events or scenario refreshes. Climate is a standing item at every Audit & Risk Committee meeting (six per year).
Board skills (Para 6(a)(ii)). Director skills matrix includes an Environment & Social category. Climate Education Sessions are scheduled into the annual director development programme; the most recent covered scenario assumptions, GHG decarbonisation pathways, and physical-risk modelling. Three of eleven Directors have prior insurance, actuarial, or climate-finance experience.
Major-transaction oversight (Para 6(a)(iv)). The CU 2.8bn five-year strategic natural-perils reinsurance arrangement was approved at Board level. M&A transactions are reviewed with explicit consideration of physical-risk concentration and transition exposure of the underlying portfolio. The Audit & Risk Committee reviews capital adequacy quarterly, including climate-stress scenario outputs.
Target oversight (Para 6(a)(v)). Board reviews progress against six Climate Action Plan targets: Net Zero Scope 1+2 by FY30, 100% renewable electricity by FY25 (achieved), 100% low-emissions tool fleet by FY30, -50% upstream operational Scope 3 by FY30, investment-portfolio carbon-intensity -50% by FY30, and the customer-side adaptation target of 1m people supported in natural-hazard risk reduction by FY25 (delivered 1.7m). Target performance feeds into Executive remuneration. [IFRS S2.33-36; 29(g)]
Management. The Group Chief Risk Officer is the executive accountable for climate-related risks. Day-to-day delivery sits with the Group Leadership Team Climate Advisory Committee (chaired by the Group Executive People, Performance & Reputation) and the Group Climate Steering Committee (operational, four meetings per year). The Group CFO is accountable for climate-related capital deployment and the reinsurance program. [IFRS S2.6(b)(i)]
Controls integration (Para 6(b)(ii)). Climate-risk monitoring is embedded into the Group Risk Management Framework and Strategy (RMFS) on a three-lines-of-defence basis: first-line risk owners in underwriting, claims, capital management, and investments; second-line risk function; third-line internal audit. The FY25 Climate-Related Risk & Opportunity Process (CRR&O) sits alongside the RMFS and feeds prioritised climate risks into divisional 3-year business plans.
Illustrative governance structure.
Cohort findings: what reporters typically skip on Para 6
Typically skipped. The dual structure of Board-level oversight and GLT-level operational committee. Most insurer disclosures name the Sustainability Committee or the Risk Committee but do not specify that climate is operationally driven through a separate cross-functional management committee. Without that distinction, Para 6(b)(i)-(ii) is described in principle, not in practice.
What good looks like. Explicit Board approval scope (CAP, reinsurance program, climate-related capex, executive incentive plans), named GLT-level operational committee, named RAS oversight body, explicit information cadence, and a target-oversight bridge to Para 29(g) remuneration linkage.
Para 7. Avoiding governance duplication with IFRS S1
Para 7 permits — but does not require — integrating climate governance with broader sustainability governance under IFRS S1’s B42(b) integration permission. The disclosure should be explicit about the integration choice and surface the climate-specific governance elements that survive integration as a separate, named list.
Standard text (verbatim, IFRS S2 Para 7)
In preparing disclosures to fulfil the requirements in paragraph 6, an entity shall avoid unnecessary duplication in accordance with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) (see paragraph B42(b) of IFRS S1). For example, although an entity shall provide the information required by paragraph 6, if oversight of sustainability-related risks and opportunities is managed on an integrated basis, the entity would avoid duplication by providing integrated governance disclosures instead of separate disclosures for each sustainability-related risk and opportunity.
Climate-related governance disclosures in Para 6 are integrated with the Group’s broader sustainability-related governance, in line with the Group’s integrated approach to climate, nature, and social risk oversight. The same Board, the same Sustainability Committee, the same GLT Climate Advisory Committee, and the same risk-management infrastructure handle all sustainability-related risks. [IFRS S2.7; IFRS S1 B42(b)]
Climate-specific governance elements that are not duplicated in the broader Sustainability Report are surfaced directly in this section: the CU 2.8bn five-year strategic natural-perils reinsurance arrangement, the FY26 Risk Appetite Statement qualitative climate statement, the 5% climate weighting in the Group Balanced Scorecard via the Short-Term Incentive plan, and the FY25 Climate-Related Risk & Opportunity Process.
Disclosure approach consistent with IFRS S1 paragraph B42(b). AU-jurisdictional note: AASB S1 was not issued alongside AASB S2; this integration framing is forward-looking for AU-only entities and current for global IFRS S1 + S2 reporters.
Cohort findings: what reporters typically skip on Para 7
Typically skipped. The list of climate-specific governance elements that survive integration. Insurance disclosures often default to “integrated approach” framing without naming the carve-outs. Without the list, the reader cannot tell whether the integrated disclosure has lost the climate-specific elements that Para 6 requires.
What good looks like. Explicit statement of integration plus a list of the climate-specific carve-outs surfaced separately. For insurance, the natural carve-outs are reinsurance program, RAS climate statement, executive incentive linkage, and the bespoke climate-risk process.
Para 10. Climate-related risks and opportunities: identification, classification, time horizons
The entity must describe its identified climate-related risks and opportunities, classify each risk as physical or transition, specify the time horizon over which each could affect the entity, and define what ‘short, medium, long term’ mean in the entity’s planning context. Time-horizon definitions must link to actual strategic-decision horizons.
Standard text (verbatim, IFRS S2 Para 10)
An entity shall disclose information that enables users of general purpose financial reports to understand the climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects. Specifically, the entity shall:
(a) describe climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects;
(b) explain, for each climate-related risk the entity has identified, whether the entity considers the risk to be a climate-related physical risk or climate-related transition risk;
(c) specify, for each climate-related risk and opportunity the entity has identified, over which time horizons (short, medium or long term) the effects of each climate-related risk and opportunity could reasonably be expected to occur;
(d) explain how the entity defines ‘short term’, ‘medium term’ and ‘long term’ and how these definitions are linked to the planning horizons used by the entity for strategic decision-making.
The Group identifies climate-related risks and opportunities at three levels: the underwriting portfolio (the largest channel), the investment portfolio, and the operational footprint. Each risk is classified as physical or transition; each is mapped to a time horizon aligned with the Group’s planning cycle (short term: 1-3 years; medium term: 3-10 years; long term: 10-30 years extending to 2050). [IFRS S2.10(a)-(d)]
| Risk / opportunity | Type | Time horizon |
|---|---|---|
| Increasing natural-perils costs (claims frequency and severity) | Physical | Short to long |
| Reinsurance availability and cost (peril-zone coverage tightening) | Physical (transmission) | Short to long |
| Operational disruption from extreme weather (claims surge capacity) | Physical | Short |
| Investment-portfolio physical-asset vulnerability | Physical | Medium to long |
| Government intervention in insurance markets (price caps, mandatory coverage, levies) | Transition | Medium to long |
| Liability risk (climate-litigation exposure under D&O, professional indemnity) | Transition (FN-IN-450a.3 third class) | Short to long |
| Investment-portfolio transition exposure (carbon-intensive industries) | Transition | Medium to long |
| Reputational risk from underwriting carbon-intensive industries | Transition | Short to medium |
| Low-carbon-tech underwriting growth (renewables, EVs, ESCO warranties) | Opportunity | Short to long |
| Resilience-clause product features (sustainable-build discounts, hardening incentives) | Opportunity | Short to medium |
| Adaptation services and customer engagement (natural-hazard risk reduction) | Opportunity | Medium to long |
The short-, medium- and long-term horizons are deliberately aligned with the Group’s three-year financial plan, ten-year strategic plan, and the 30-year long-term horizon used for reinsurance-treaty repricing and IFRS 17 long-tail liability accumulation. [IFRS S2.10(d)]
Illustrative risk universe drawn from sector practice.
Cohort findings: what reporters typically skip on Para 10
Typically skipped. The link between time-horizon definitions and the entity’s actual planning artefacts (Para 10(d)). Many insurer disclosures use ST/MT/LT without saying what those mean to the company’s own decision-making. Also typically skipped: explicit treatment of liability risk as a distinct exposure (FN-IN-450a.3 third class).
What good looks like. A risk-and-opportunity table with explicit physical/transition classification, time-horizon assignment, and a paragraph linking each horizon to a planning artefact (financial plan, strategic plan, reinsurance repricing cycle, IFRS 17 long-tail accumulation). Liability risk should be classified explicitly with cross-reference to FN-IN-450a.3.
Para 13. Effects of climate-related risks and opportunities on the business model and value chain
Disclose the current and anticipated effects of climate-related risks and opportunities on the business model and value chain, and where in the value chain those risks and opportunities are concentrated — by geography, facility, asset type. Concentration disclosure is the load-bearing element; high-level narrative without geography or asset specificity does not satisfy the standard.
Standard text (verbatim, IFRS S2 Para 13)
An entity shall disclose information that enables users of general purpose financial reports to understand the current and anticipated effects of climate-related risks and opportunities on the entity’s business model and value chain. Specifically, the entity shall disclose:
(a) a description of the current and anticipated effects of climate-related risks and opportunities on the entity’s business model and value chain;
(b) a description of where in the entity’s business model and value chain climate-related risks and opportunities are concentrated (for example, geographical areas, facilities and types of assets).
The Group’s business model spans general insurance underwriting (CU 14bn gross written premium across retail and intermediated channels in Australia and New Zealand), an investment portfolio (CU 18bn AUM funded by premium reserves and shareholder capital), and an operational footprint (38 corporate sites, ~14,000 employees). The dominant climate-exposed channel is the underwriting portfolio. [IFRS S2.13(a)-(b)]
Anticipated effects (Para 13(a)). Under medium-warming (SSP2-4.5 by 2050), natural-perils costs on the AU portfolio rise materially, driving reinsurance-program cost pressure and selective addressable-market reduction in highest-exposure peril zones. Under high-warming (SSP5-8.5 by 2050), reinsurance availability tightens further and government intervention in insurance markets (price caps, mandatory coverage, levies) becomes more probable. The investment portfolio sees physical-asset vulnerability rise across geographically concentrated holdings and transition write-downs in carbon-intensive industries.
Concentration of climate-related risks (Para 13(b)).
| Concentration dimension | Detail |
|---|---|
| Geography (premium) | Australia 75% (retail consumer brands plus intermediated commercial brands); New Zealand 25% (NZ subsidiary brands) |
| Geography (peril concentration) | Tropical cyclone: north-east QLD, north-west WA, southward expansion to south-east QLD; bushfire: south-east AU urban-rural interface, south-west WA; east coast lows: NSW, eastern VIC; flood: south-east QLD, north NSW |
| Product mix | Property & casualty 88% (motor 41%, home 32%, commercial 15%); intermediated commercial 12%; no direct life insurance exposure |
| Distribution channel | Retail 64% (direct, branch, digital); intermediated 36% (broker, agent, partner); B2C and B2B across AU+NZ |
| Investment portfolio (CU 18bn AUM) | Equities 24% (ASX200 ex-self + MSCI World); fixed income 64% (AU government, AU corporate, global investment-grade); green bonds 1.4% (CU 250m); cash 11% |
| Operational footprint | 38 corporate sites; 5 sites in elevated physical-risk regions (CU 18m PP&E carrying amount, ~6% of operational PP&E) |
Value chain: upstream is the reinsurance counterparty network (concentrated in five global reinsurers under the strategic natural-perils arrangement) and broker distribution channel. Downstream is the claims supply chain (repair networks, motor parts, building trades, surge-capacity providers for major-event weeks). Both directions carry climate-related concentration that affects claims-cost trajectory and operational continuity.
Illustrative concentration figures.
Cohort findings: what reporters typically skip on Para 13
Typically skipped. Peril-clustering geographic concentration. Insurer disclosures often describe national exposure (AU/NZ) but not the within-country peril clustering (TC NE/NW; bushfire SE/SW; ECL east coast). Without that detail, Para 13(b) is described in principle but not in operational specificity. Also typically skipped: investment-portfolio dimension and value-chain (reinsurance counterparties + claims supply chain) concentration.
What good looks like. Multi-dimensional concentration table (geography × peril × product × distribution × investment + footprint) with explicit anticipated-effects narrative connecting concentration to the reinsurance-cost / addressable-market / government-intervention transmission channels.
Para 14. Strategy and decision-making, including transition plan
Disclose how the entity has responded to and plans to respond to climate-related risks in its strategy and decision-making — including business-model changes, direct and indirect mitigation and adaptation efforts, and any transition plan with its assumptions and dependencies. Disclose how the entity is resourcing these activities and progress against prior-period plans.
Standard text (verbatim, IFRS S2 Para 14)
An entity shall disclose information that enables users of general purpose financial reports to understand the effects of climate-related risks and opportunities on its strategy and decision-making. Specifically, the entity shall disclose:
(a) information about how the entity has responded to, and plans to respond to, climate-related risks and opportunities in its strategy and decision-making, including how the entity plans to achieve any climate-related targets it has set and any targets it is required to meet by law or regulation. Specifically, the entity shall disclose information about:
(i) current and anticipated changes to the entity’s business model, including its resource allocation, to address climate-related risks and opportunities (for example, plans to manage or decommission carbon-, energy- or water-intensive operations; resource allocations resulting from demand or supply-chain changes; resource allocations arising from business development through capital expenditure or research and development; and acquisitions or divestments);
(ii) current and anticipated direct mitigation and adaptation efforts (for example, through changes in production processes or equipment, relocation of facilities, workforce adjustments, and changes in product specifications);
(iii) current and anticipated indirect mitigation and adaptation efforts (for example, through working with customers and supply chains);
(iv) any climate-related transition plan the entity has, including information about key assumptions used in developing its transition plan, and dependencies on which the entity’s transition plan relies;
(v) how the entity plans to achieve any climate-related targets, including any greenhouse gas emissions targets, described in accordance with paragraphs 33-36.
(b) information about how the entity is resourcing, and plans to resource, the activities disclosed in accordance with paragraph 14(a).
(c) quantitative and qualitative information about the progress of plans disclosed in previous reporting periods in accordance with paragraph 14(a).
The Group’s strategic response to climate-related risks and opportunities is built on three layers: capital protection through reinsurance, decarbonisation of own operations and investment portfolio, and customer-side adaptation through partnerships and product features. The Group’s Climate Action Plan (CAP), updated August 2024, anchors the response. [IFRS S2.14(a); 14(a)(iv) transition plan]
Business model changes (Para 14(a)(i)). The Group entered a five-year strategic natural-perils reinsurance arrangement providing up to CU 2.8bn of volatility protection for natural-perils losses, alongside whole-of-account quota share arrangements. This is the largest single capital-management lever for climate volatility. Selected pricing and product-withdrawal action in highest-exposure peril zones is in scope under the broader underwriting-discipline framework.
Direct mitigation and adaptation (Para 14(a)(ii)). Operations: 100% renewable electricity achieved FY25; 100% low-emissions tool-fleet by FY30 in progress (current 63% of fleet hybrid or EV). Investment portfolio decarbonisation: ASX200 ex-self normalised carbon footprint reduced 69% from FY20 baseline; MSCI World equivalent reduced 60%. Fleet electrification across AU and NZ.
Indirect mitigation and adaptation (Para 14(a)(iii)). Customer-side adaptation: 1m people supported in natural-hazard risk reduction by FY25 (delivered 1.7m, exceeding target). Industry advocacy with the Insurance Council of Australia, Insurance Council of New Zealand, and government on land-use planning, building codes, and disaster-resilience funding. Three-year educational partnership with the US National Center for Atmospheric Research producing the Severe Weather in a Changing Climate report (3rd edition Nov 2025).
Transition plan (Para 14(a)(iv)). CAP six targets, key assumptions and dependencies set out in section 1.4. Net Zero target methodology has not yet been validated by SBTi (validation in progress). Carbon-credit reliance: not used in the FY25 reporting period; future use governed by a 10% cap on residual emissions with Verra or Gold Standard verification requirements.
Achieving targets (Para 14(a)(v)). Per Para 33-36, six CAP targets feed into Executive remuneration through the Group Balanced Scorecard (5% climate weighting in FY25; broader Divisional BSC integration in FY26).
Resourcing (Para 14(b)). CU 2.8bn reinsurance arrangement is a 5-year capital commitment. Operational decarbonisation capex CU 35-50m to 2030. Investment-portfolio reallocation flow to green bonds: CU 250m current, CU 200m target floor.
Progress against prior-period plans (Para 14(c)). FY25 milestones from the FY24 CAP review: renewable electricity 100% achieved (target FY25, met); investment portfolio carbon footprint AU -69% / global -60% vs FY20 baseline (target -25% by FY25, exceeded); 1m people supported in natural-hazard reduction (target FY25, exceeded at 1.7m); enterprise climate awareness campaign delivered (target FY25, met).
Illustrative strategy structure.
Cohort findings: what reporters typically skip on Para 14
Typically skipped. Para 14(c) progress against prior-period plans. Most first-cycle disclosures don’t have a prior cycle to report against. Even where TCFD-based plans exist, the 14(c) bridge from prior-period commitment to current-period delivery isn’t always made. Also typically skipped: the customer-side indirect-adaptation lever, where many insurer disclosures focus on operational decarbonisation but not the customer-engagement adaptation channel.
What good looks like. Explicit progress narrative with named milestones, achieved-vs-target indicator per milestone, and the customer-side indirect-adaptation target surfaced as a strategic lever (not just a community-engagement metric).
Para 15–21. Anticipated financial effects on financial position, performance and cash flows
Disclose how climate-related risks and opportunities have affected financial position, performance, and cash flows for the reporting period (current effects), and anticipated effects over short, medium, and long term. Para 19-21 permit qualitative-only disclosure where quantification is not separately identifiable, measurement uncertainty is too high, or the entity lacks skills and resources — but the qualitative substitute must explain the omission and identify affected line items.
Standard text (verbatim, IFRS S2 Para 15–21)
An entity shall disclose information that enables users to understand:
(a) the effects of climate-related risks and opportunities on the entity’s financial position, financial performance and cash flows for the reporting period (current financial effects);
(b) the anticipated effects of climate-related risks and opportunities on the entity’s financial position, financial performance and cash flows over the short, medium and long term (anticipated financial effects).
Specifically, an entity shall disclose quantitative and qualitative information about:
(a) how climate-related risks and opportunities have affected its financial position, financial performance and cash flows for the reporting period;
(b) the climate-related risks and opportunities identified in paragraph 16(a) for which there is a significant risk of a material adjustment within the next annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements;
(c) how the entity expects its financial position to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities, taking into consideration:
(i) its investment and disposal plans, including plans the entity is not contractually committed to;
(ii) its planned sources of funding to implement its strategy;
(d) how the entity expects its financial performance and cash flows to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities.
In providing quantitative information, an entity may disclose a single amount or a range.
In preparing disclosures about the anticipated financial effects of a climate-related risk or opportunity, an entity shall:
(a) use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort;
(b) use an approach that is commensurate with the skills, capabilities and resources that are available to the entity for preparing those disclosures.
An entity need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity if the entity determines that:
(a) those effects are not separately identifiable; or
(b) the level of measurement uncertainty involved in estimating those effects is so high that the resulting quantitative information would not be useful.
In addition, an entity need not provide quantitative information about the anticipated financial effects of a climate-related risk or opportunity if the entity does not have the skills, capabilities or resources to provide that quantitative information.
If an entity determines that it need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity applying the criteria set out in paragraphs 19-20, the entity shall:
(a) explain why it has not provided quantitative information;
(b) provide qualitative information about those financial effects, including identifying line items, totals and subtotals within the related financial statements that are likely to be affected, or have been affected, by that climate-related risk or opportunity;
(c) provide quantitative information about the combined financial effects of that climate-related risk or opportunity with other climate-related risks or opportunities and other factors unless the entity determines that quantitative information about the combined financial effects would not be useful.
Climate-related risks and opportunities affect the Group’s financial position, performance, and cash flows through the underwriting portfolio (claims expense, premium pricing, reinsurance recoverables), the investment portfolio (asset valuation, equity returns), and the capital adequacy ratio. The Group’s assessment of the potential financial impacts of climate-related risks continues to mature, and quantitative information about anticipated effects is not yet provided. The Group invokes the Para 19 and Para 20 carve-outs and meets the Para 21 substitute-disclosure requirements for the preparatory FY25 cycle ahead of mandatory AASB S2 reporting from FY26. [IFRS S2.15-21]
Para 21(a) explanation. Quantitative information is not provided because (i) under Para 19, climate-driven impacts on natural-perils claims experience are not separately identifiable from baseline year-on-year volatility, and measurement uncertainty in scenario-driven projections of premium pricing, claims frequency, and reinsurance availability is too high to produce useful quantitative information at the entity level; and (ii) under Para 20, the Group does not yet have the skills, capabilities, or resources to provide quantitative anticipated-effects disclosures at the required granularity. The methodology is being calibrated alongside the FY25 Climate-Related Risk & Opportunity Process ahead of mandatory AASB S2 reporting from FY26.
Para 21(b) qualitative information and line-item identification. The financial-statement line items most likely to be affected by climate-related risks and opportunities are:
| Line item | Channel | Direction |
|---|---|---|
| Claims expense (current period) | Natural-perils event frequency and severity | Upward; volatility |
| Reinsurance recoverable | Treaty terms; cedent willingness | Variable; cost-up under high-warming |
| Gross written premium / premium-rate adequacy | Risk-based pricing; addressable-market sensitivity | Upward (price); downward (volume in highest-exposure zones) |
| Capital adequacy ratio (CPS 220) | RAS climate qualitative buffer | Tighter buffer requirement under SSP5-8.5 |
| Investment portfolio asset valuation | Transition-risk write-downs; physical-risk exposure | Variable; mixed by sector and geography |
| Earnings.fair value through P&L | Marked-to-market on equities and corporate fixed income | Variable |
| Provisions (IFRS 17 onerous-contract test) | Multi-year peril-cost trend | Upward under high-warming |
Para 21(c) combined-effect quantitative information. Combined-effect quantitative disclosure is not provided because the Group has determined the resulting figure would not be useful for comparability across reporting periods, given the early-stage methodology calibration. The Group expects to provide quantitative range disclosure under Para 17 from FY27 onwards, following completion of the second cycle of the CRR&O Process and integration with reinsurance-program pricing analysis.
Significant uncertainties (cross-reference Para 22(a)(ii)). Liability-risk political evolution, government-intervention timing and shape, EV adoption rates affecting motor-portfolio claims, future natural-perils cost growth across the four AU regions identified in the Severe Weather report, and reinsurance availability under high-warming scenarios.
Illustrative line items.
Cohort findings: what reporters typically skip on Para 15–21
Typically skipped. The line-item table identifying which financial-statement items the qualitative effect applies to. Insurer disclosures often invoke the Para 21 escape but do not satisfy 21(b) which requires line-item identification. Also typically skipped: the path to quantitative disclosure (when the Para 21 carve-out will be retired). Without that path, the carve-out reads as permanent rather than transitional.
What good looks like. Para 21 invoked with rationale; line-item table with reinsurance recoverable distinctly named; explicit timeline for moving to quantitative range disclosure under Para 17.
Para 22. Climate resilience: scenario analysis disclosure ★
Para 22 requires the entity to assess and disclose how resilient its strategy and business model are to climate-related changes, using climate-related scenario analysis. The standard calls for a ‘diverse range’ of scenarios including one aligned with the latest international climate agreement, with disclosure covering scenario inputs, key assumptions, time horizons, and the entity’s capacity to adapt. This is the load-bearing strategy paragraph.
Standard text (verbatim, IFRS S2 Para 22)
An entity shall disclose information that enables users of general purpose financial reports to understand the resilience of the entity’s strategy and business model to climate-related changes, developments and uncertainties, taking into consideration the entity’s identified climate-related risks and opportunities. The entity shall use climate-related scenario analysis to assess its climate resilience using an approach that is commensurate with the entity’s circumstances (see paragraphs B1-B18). In providing quantitative information, the entity may disclose a single amount or a range. Specifically, the entity shall disclose:
(a) the entity’s assessment of its climate resilience as at the reporting date, which shall enable users to understand:
(i) the implications, if any, of the entity’s assessment for its strategy and business model, including how the entity would need to respond to the effects identified in the climate-related scenario analysis;
(ii) the significant areas of uncertainty considered in the entity’s assessment of its climate resilience;
(iii) the entity’s capacity to adjust or adapt its strategy and business model to climate change over the short, medium and long term, including:
(1) the availability of, and flexibility in, the entity’s existing financial resources to respond to the effects identified in the climate-related scenario analysis, including to address climate-related risks and to take advantage of climate-related opportunities;
(2) the entity’s ability to redeploy, repurpose, upgrade or decommission existing assets;
(3) the effect of the entity’s current and planned investments in climate-related mitigation, adaptation and opportunities for climate resilience;
(b) how and when the climate-related scenario analysis was carried out, including:
(i) information about the inputs the entity used, including:
(1) which climate-related scenarios the entity used for the analysis and the sources of those scenarios;
(2) whether the analysis included a diverse range of climate-related scenarios;
(3) whether the climate-related scenarios used for the analysis are associated with climate-related transition risks or climate-related physical risks;
(4) whether the entity used, among its scenarios, a climate-related scenario aligned with the latest international agreement on climate change;
(5) why the entity decided that its chosen climate-related scenarios are relevant to assessing its resilience to climate-related changes, developments or uncertainties;
(6) the time horizons the entity used in the analysis;
(7) what scope of operations the entity used in the analysis (for example, the operating locations and business units used in the analysis);
(ii) the key assumptions the entity made in the analysis, including assumptions about:
(1) climate-related policies in the jurisdictions in which the entity operates;
(2) macroeconomic trends;
(3) national- or regional-level variables (for example, local weather patterns, demographics, land use, infrastructure and availability of natural resources);
(4) energy usage and mix;
(5) developments in technology;
(iii) the reporting period in which the climate-related scenario analysis was carried out (see paragraph B18).
The Group assessed the resilience of its strategy and business model by running scenario analysis on the underwriting portfolio (claims-cost trajectory under each scenario × peril combination) and the investment portfolio (asset-vulnerability exposure). Three scenarios used: Orderly Net Zero 2050 (Paris-aligned), Disorderly Delayed Transition (NDC-aligned), and Hot House World Current Policies (limited-action). Scope: all underwritten policies and AUM. Reporting period: bi-annual refresh; current cycle completed in FY25 ahead of mandatory FY26 disclosure. [IFRS S2.22; B1-B18]
| Scenario | Source | Key assumptions | Time horizon | Physical risk magnitude | Transition risk magnitude | Resilience implication |
|---|---|---|---|---|---|---|
| Orderly: Net Zero 2050 | NGFS Phase IV NZ 2050 + IPCC RCP1.9; AEMO ISP 2024 (energy mix); CSIRO EV Projection 2023 | 1.5°C trajectory by 2050 (1.4°C by 2100); coordinated policy; rapid renewables build-out; EV fleet share AU+NZ 46-95% by 2050 | 2030 / 2050 | Mild (peril cost growth slow; chronic stress moderate) | Elevated (carbon-pricing exposure on investee portfolio; rapid retail-customer behaviour shift; legacy-vehicle insurance demand decline) | Manageable; reinsurance and capital absorb central case; investment-portfolio decarbonisation aligned with policy shift; addressable market resilient |
| Disorderly: Delayed Transition | NGFS Phase IV NDC + IPCC RCP2.6; Insurance Council of NZ Climate Scenarios for NZ General Insurance Sector 2022 | <2.0°C by 2050 (1.7°C by 2100); delayed policy action then sudden tightening; physical-risk frequency rises through 2030s | 2030 / 2050 | Moderate by 2030; elevated by 2050 | Moderate (gradual policy tightening; sectoral-decarbonisation pressure; investment-portfolio re-rating) | Manageable through 2030; physical-perils claims cost on AU portfolio rises CU 200-400m per year by 2050; reinsurance program repricing required; investment portfolio sees mid-term volatility |
| Hot House World: Current Policies | NGFS Phase IV Current Policies modified to RCP7.0; NZ Climate Change Commission 2021 Draft Advice (NZ overlay) | >2.0°C by 2050 (3.9°C by 2100); little new climate policy; physical-risk frequency and severity rise materially | 2030 / 2050 | Severe (acute frequency-and-intensity rise materially; insurability stress in highest-exposure peril zones) | Low regulatory but elevated litigation and addressable-market constraint risk if policy reversal materialises | Stress on AU portfolio becomes material from 2040; reinsurance availability tightens; government intervention in insurance markets becomes probable; addressable-market reduction in coastal and bushfire-urban-interface zones |
Per-peril sensitivity (Severe Weather report taxonomy). Tropical Cyclone risk rises most in southwest WA, southeast QLD to northern NSW (intensification with slower forward speed). Extreme precipitation and flash-flood frequency rises materially in urban regions (compound with sea-level rise effects). Severe convective storms and large-hail risk increases over densely populated southern AU (Melbourne-Sydney-Brisbane corridor). Mid-latitude lows / east coast lows decrease in frequency but intensify. Bushfire-weather risk escalates faster than climate models predicted (fastest of the seven perils). Sea-level rise tracks high-emissions trajectory (RCP7.0); 0.26m by 2050. Compound events (multiple perils same location in close succession) amplify total loss costs.
22(a)(i) implications for strategy and business model. Reinsurance program is the primary capital-management lever; the CU 2.8bn five-year strategic arrangement reduces volatility under the central case (Disorderly) and the high-warming case (Hot House). Investment-portfolio decarbonisation under Orderly accelerates; under Hot House, investment-portfolio physical-asset vulnerability rises. Customer-side adaptation programme (1m people supported) becomes load-bearing for addressable-market retention in highest-exposure zones.
22(a)(ii) significant uncertainties. Liability-risk political evolution (D&O litigation under transition); type and timing of government intervention in insurance markets; EV adoption rates affecting motor portfolio; future natural-perils cost growth, especially compound events; reinsurance availability under all scenarios but at increased cost.
22(a)(iii) capacity to adjust. (1) Financial resources: reinsurance and capital absorb central case; existing capital position sufficient under Orderly and Disorderly across all horizons; tighter under Hot House LT. (2) Asset redeploy: investment-portfolio reallocation horizon 3-5 years; underwriting-portfolio repricing cycle annual to triennial. (3) Effect of planned investments: CU 2.8bn reinsurance arrangement provides volatility cover; CU 250m green-bond floor; customer-side adaptation programme aligned with addressable-market retention.
Illustrative analysis.
Cohort findings: what reporters typically skip on Para 22
Typically skipped. Per-peril resilience-implication numbers under each scenario. Insurer disclosures describe the scenario set and the methodology but stop short of the per-scenario × per-peril cost trajectory required by Para 22(a)(i)-(iii). Also typically skipped: the 22(b)(ii) key-assumptions disclosure (energy mix, EV adoption, technology cost curves, regulatory-policy assumptions per scenario), and the link to reinsurance-program design (insurers run scenario analysis for treaty negotiation but rarely surface the connection in the climate disclosure).
What good looks like. 3-row × 7-col scenario table; per-peril sensitivity narrative anchored to a published peril-science source; explicit 22(a)(iii) financial-resources / asset-flexibility / planned-investment narrative; cross-reference to reinsurance-program design and FN-IN-450a.1 PML methodology.
Para 25. Risk management: processes for identifying, assessing, prioritising and monitoring climate-related risks
Disclose the processes the entity uses to identify, assess, prioritise, and monitor climate-related risks (and separately, opportunities) — including data sources, scope of operations covered, scenario-analysis use in identification, materiality criteria, and how climate-risk processes integrate into the overall risk-management framework. Disclose any process changes from the prior reporting period.
Standard text (verbatim, IFRS S2 Para 25)
To achieve this objective, an entity shall disclose information about:
(a) the processes and related policies the entity uses to identify, assess, prioritise and monitor climate-related risks, including information about:
(i) the inputs and parameters the entity uses (for example, information about data sources and the scope of operations covered in the processes);
(ii) whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related risks;
(iii) how the entity assesses the nature, likelihood and magnitude of the effects of those risks (for example, whether the entity considers qualitative factors, quantitative thresholds or other criteria);
(iv) whether and how the entity prioritises climate-related risks relative to other types of risk;
(v) how the entity monitors climate-related risks;
(vi) whether and how the entity has changed the processes it uses compared with the previous reporting period;
(b) the processes the entity uses to identify, assess, prioritise and monitor climate-related opportunities, including information about whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related opportunities;
(c) the extent to which, and how, the processes for identifying, assessing, prioritising and monitoring climate-related risks and opportunities are integrated into and inform the entity’s overall risk management process.
The Group’s processes to identify, assess, prioritise, and monitor climate-related risks are dual-track: the existing Risk Management Framework and Strategy (RMFS) handles climate as a causal factor in Insurance Risk and as a standalone Strategic Risk class; a bespoke FY25 Climate-Related Risk & Opportunity Process (CRR&O) sits alongside the RMFS and produces prioritised divisional climate plans. [IFRS S2.25]
Inputs and parameters (Para 25(a)(i)). Underwriting-portfolio peril exposure (12 physical hazards × geographic region × policy concentration); investment-portfolio carbon-intensity and physical-vulnerability data (third-party climate data providers and internal asset-coordinate data); claims-frequency time series; reinsurance-program structure data; APRA Prudential Standard CPS 220 capital adequacy framework. The CRR&O Process draws subject-matter expertise from Group Risk, Actuarial, Underwriting, Claims, Investments, and Government & Industry Affairs.
Use of scenario analysis (Para 25(a)(ii)). Para 22 scenario outputs (NGFS Phase IV + AEMO ISP + CSIRO + ICNZ + NZ CCC) feed both the underwriting-side claims-cost trajectory analysis (via FN-IN-450a.1 PML methodology) and the investment-portfolio physical-and-transition vulnerability mapping. Scenario outputs are integrated into the Strategic Risk Profile (SRP) and the Risk Appetite Statement (RAS) qualitative climate statement (CPS 220).
Assessment (Para 25(a)(iii) nature, likelihood, magnitude). The CRR&O Process adopts a quantitative-first approach. Materiality threshold: a percentage of projected Net Profit After Tax (NPAT) over short-, medium-, and long-term horizons. Future impact assessments are conducted on a present-value basis, with certain macro factors (including future inflation) excluded to avoid obscuring climate-specific factors. Qualitative materiality is invoked where quantitative assessment is uncertain or where qualitative considerations indicate materiality.
Prioritisation (Para 25(a)(iv)). Climate is a Tier 1 risk in the Strategic Risk Profile (failure-to-prepare risk for AASB S2 / climate change). Climate is also a causal factor in Insurance Risk (claims experience), Operational Risk (business disruption), Regulatory & Compliance Risk, and Financial Risk (reinsurance coverage, investment exposure). Prioritisation against other strategic risks is performed through the annual SRP refresh.
Monitoring (Para 25(a)(v)). Annual SRP refresh; quarterly Risk Impact Matrix updates; ongoing risk-event identification; geographic aggregate-concentration exposure monitoring; RAS tolerance proximity monitoring; Major Events Management process (Group Claims Management Policy) for natural-perils events. Group-level enterprise risk dashboard maintained for Board Risk Committee review at every cycle.
Process changes (Para 25(a)(vi)). In FY25, the Group made the following changes to risk-management processes: (i) introduced the Climate-Related Risk & Opportunity Process (CRR&O) alongside the RMFS; (ii) updated the RMFS to reflect climate-specific governance escalation pathways; (iii) updated the Group RAS for FY26 to include a qualitative statement on integration of climate-related physical and transition risks; (iv) introduced specific climate-risk monitoring at risk-event, risk-profile, and risk-control level.
Opportunities processes (Para 25(b)). The CRR&O Process applies the same identification and assessment to climate-related opportunities. Opportunities are prioritised through 3-year Divisional Business Plans with planned initiatives in low-carbon-tech underwriting, resilience-clause product development, and adaptation-services partnerships. The divisional Quarterly Business Review (QBR) tracks delivery progress.
Integration (Para 25(c)). The dual-track design integrates climate within the existing Insurance Risk and Strategic Risk classes (RMFS), and produces additional prioritised climate plans through the CRR&O. Both feed the same Board Risk Committee and the same RAS oversight cycle.
Illustrative process structure.
Cohort findings: what reporters typically skip on Para 25
Typically skipped. Para 25(a)(vi) changed processes. First-cycle reporters often describe the new process but don’t name it as a change vs the prior period. Also typically skipped: the dual-track distinction between RMFS (BAU) and CRR&O (climate-specific). Insurer disclosures often describe one track and conflate the two, losing the insight that climate is treated both as a causal factor in BAU risk classes and as a standalone strategic risk.
What good looks like. Explicit dual-track description; named year-on-year process changes; explicit materiality threshold methodology (quantitative-first with NPAT proxy); integration narrative tied to RAS and CPS 220 cycles.
Para 29(a). Greenhouse gas emissions: Scope 1, 2, 3 (with financed-emissions limitation 29A-C)
Disclose absolute gross GHG emissions in CO2-equivalent for Scope 1, 2, and 3, measured per the GHG Protocol Corporate Standard. For Scope 1 and 2, disaggregate consolidated group from associates, joint ventures, and unconsolidated subsidiaries. For Scope 2, disclose location-based emissions plus contractual-instrument detail. For Scope 3, disclose categories per the GHG Protocol Value Chain Standard, with additional financed-emissions detail for asset managers, banks, and insurers (Para 29A-C optional limitation applies).
Standard text (verbatim, IFRS S2 Para 29(a))
Greenhouse gases. The entity shall:
(i) disclose its absolute gross greenhouse gas emissions generated during the reporting period, expressed as metric tonnes of CO2 equivalent, classified as:
(1) Scope 1 greenhouse gas emissions;
(2) Scope 2 greenhouse gas emissions;
(3) Scope 3 greenhouse gas emissions;
(ii) measure its greenhouse gas emissions in accordance with the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) unless the entity is required, in whole or in part, by a jurisdictional authority or an exchange on which it is listed to use a different method for measuring its greenhouse gas emissions;
(iii) disclose the approach it uses to measure its greenhouse gas emissions, including:
(1) the measurement approach, inputs and assumptions the entity uses;
(2) the reason why the entity has chosen those;
(3) any changes the entity made to the measurement approach, inputs and assumptions during the reporting period and the reasons for those changes;
(iv) for Scope 1 and Scope 2 greenhouse gas emissions, disaggregate emissions between:
(1) the consolidated accounting group;
(2) other investees excluded from paragraph 29(a)(iv)(1) (associates, joint ventures and unconsolidated subsidiaries);
(v) for Scope 2 greenhouse gas emissions, disclose its location-based Scope 2 greenhouse gas emissions, and provide information about any contractual instruments that is necessary to inform users’ understanding of the entity’s Scope 2 greenhouse gas emissions;
(vi) for Scope 3 greenhouse gas emissions disclose:
(1) the categories included within the entity’s measure of Scope 3 greenhouse gas emissions, in accordance with the Scope 3 categories described in the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011);
(2) additional information about the entity’s financed emissions (which are part of Category 15 greenhouse gas emissions), if its activities include asset management, commercial banking or insurance. Paragraphs 29A-29C govern an optional limitation of Category 15 to financed emissions.
The Group’s gross greenhouse-gas emissions for the reporting period are disclosed below in metric tonnes of CO2 equivalent, measured per the GHG Protocol Corporate Accounting and Reporting Standard. Operational emissions are small relative to potential investment-portfolio financed emissions; Scope 3 Category 15 (financed emissions) is not yet measured. [IFRS S2.29(a); 29A-29C]
| Scope | Category | FY25 (tCO2e) | Coverage |
|---|---|---|---|
| Scope 1 | Direct emissions (company vehicles, natural gas, stationary LPG, refrigerant gases) | 6,770 | Group |
| Scope 2 (location-based) | Purchased electricity | 12,045 | Group |
| Scope 2 (market-based) | Purchased electricity, net of contractual instruments | 5,429 | Group |
| Scope 3 Cat 1 | Purchased goods and services (print, office paper, data-centre electricity) | 3,189 | Group, limited |
| Scope 3 Cat 3 | Fuel- and energy-related activities (transmission and distribution losses) | 2,252 | Group, limited |
| Scope 3 Cat 5 | Waste generated in operations | 1,684 | Group, limited |
| Scope 3 Cat 6 | Business travel (air, taxi, rental, staff mileage) | 5,182 | Group, limited |
| Scope 3 Cat 7 | Employee commuting (incl. work-from-home) | 7,076 | Group, limited |
| Scope 3 Cat 13 | Downstream leased assets | n/a | Not yet captured |
| Scope 3 Cat 15 | Investments / financed emissions | n/a | Not yet captured (Para 29A-C limitation under consideration) |
| Total gross GHG emissions | (Scope 1 + Scope 2 LB + Scope 3 limited) | 38,198 | Group |
| Carbon credits used | n/a | 0 | Group |
| Net GHG emissions (using market-based Scope 2) | (Scope 1 + Scope 2 MB + Scope 3 limited) | 31,582 | Group |
Para 29A-29C limitation option (insurance). Para 29A explicitly permits insurance entities to limit Scope 3 Cat 15 to emissions attributed to investments (excluding derivatives). The Group has not yet applied the limitation because Cat 15 measurement is not yet operational; the Group will disclose under Para 29B (activities excluded as derivatives) and Para 29C (financed-emissions subtotal within Cat 15) once measurement is in place, expected from FY27.
Measurement approach (Para 29(a)(iii)). Emission factors drawn from DEFRA Conversion Factors 2024, NZ MfE 2024 emission factors, and Australian National Greenhouse Account Factors. Methodology aligned with the GHG Protocol Corporate Accounting and Reporting Standard (revised edition) and the Corporate Value Chain (Scope 3) Accounting and Reporting Standard. Methodology revisions in the current period: NZ MfE 2024 update applied with one-year-arrears restatement; Scope 3 Cat 1 emission factor revised to DEFRA 2024.
Disaggregation (Para 29(a)(iv)). Group disclosure covers the consolidated accounting group. Specific subsidiaries excluded due to current data limitations are noted in measurement footnotes. Other investees (associates, joint ventures, unconsolidated subsidiaries) are not disclosed separately as they are not material.
The Group’s external auditor provides limited assurance over Scope 1, Scope 2 (location-based and market-based), Scope 3 categories, total gross, and net GHG emissions, per ISAE 3000/3410.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(a)
Typically skipped. Para 29A-C disclosure for insurers who have not yet measured Cat 15. Many simply omit the narrative; the disclosure should explicitly state that Cat 15 is not yet captured and that the Para 29A-C limitation option is under consideration. Also typically skipped: methodology revision disclosure (Para 29(a)(iii)) when emission factors are updated mid-cycle.
What good looks like. Full Scope 1/2/3 table with both location-based and market-based Scope 2; Cat 13/15 explicit ‘not yet captured’ line; named methodology and emission-factor sources; methodology revision narrative with prior-period restatement; assurance scope statement.
Para 29(b). Climate-related transition risks: assets and business activities vulnerable
The amount and percentage of assets or business activities vulnerable to climate-related transition risks. Vulnerability must be defined against named transition-risk drivers (carbon pricing, technology shifts, demand decline, regulation tightening) under specified scenarios. Without a defined threshold and named scenario, the percentage figure is unverifiable.
Standard text (verbatim, IFRS S2 Para 29(b))
Climate-related transition risks. The amount and percentage of assets or business activities vulnerable to climate-related transition risks.
The Group discloses the amount and percentage of investment-portfolio assets and underwriting business activities vulnerable to climate-related transition risks under each scenario in the Para 22 set, as at the reporting date. Vulnerability is assessed at the underlying-investee or insured-counterparty level using a sector-and-geography transition-risk overlay. [IFRS S2.29(b); 30]
| Exposure type | Amount under Disorderly 2050 (CU) | % of base | Dominant transition driver |
|---|---|---|---|
| Investment portfolio (AU + global equities + AU corporate fixed income) | 2.1bn | 11.7% of AUM | Fossil-fuel value chain; carbon-intensive heavy industry; legacy automotive |
| Underwriting GWP.commercial lines exposure to carbon-intensive industries | 1.0bn | 7.1% of GWP | Energy generation, oil & gas services, heavy haulage, manufacturing fleet |
Investment-portfolio carbon-footprint trajectory. Normalised carbon footprint of the equity portfolio reduced 69% (AU equities, ASX200 ex-self) and 60% (global equities, MSCI World) versus the FY20 baseline. Weighted-average carbon intensity reduced 64% (AU) and 54% (global) versus FY20. Performance against Para 33-36 Target 4 (-25% by FY25, -50% by FY30): exceeded ahead of schedule.
Vulnerability is determined using sector classification (GICS) plus a transition-risk-score overlay (third-party data provider) per investee. The percentage figure is gross of any planned investment-portfolio reallocation. Underwriting GWP exposure is tracked at the broker-channel level for commercial lines and at the policy-class level for retail.
Illustrative figures. The Continuuiti Climate Risk service produces both investment-portfolio asset-level transition-risk vulnerability and underwriting-counterparty transition-risk overlays.
Cohort findings: what reporters typically skip on Para 29(b)
Typically skipped. Underwriting GWP exposure to transition risks. Insurer disclosures lead with investment-portfolio decarbonisation but omit the underwriting-side transition exposure (commercial-lines policies covering carbon-intensive industries). Also typically skipped: scenario-conditioned ranges. Often a single figure is given without showing how 29(b) shifts across the Para 22 scenarios — losing the Orderly-vs-Hot-House inversion that is itself informative.
What good looks like. Amount + percentage form for both investment portfolio and underwriting business activities; multi-scenario ranges (Orderly / Disorderly / Hot House); explicit driver disaggregation; trajectory tied to Para 33-36 targets.
Para 29(c). Climate-related physical risks: assets and business activities vulnerable ★
The amount and percentage of assets or business activities vulnerable to climate-related physical risks. The most-skipped disclosure across every first-wave reporter cohort globally — about a third to a half of reporters either omit the quantitative figure or substitute a qualitative hedge. The amount-and-percentage form is the load-bearing element; vulnerability threshold, scenario, and time horizon must be disclosed alongside. Iris unpacks the four definitional ambiguities buried in the standard’s amount-and-percentage language in a separate Para 29(c) deep-dive.
Standard text (verbatim, IFRS S2 Para 29(c))
Climate-related physical risks. The amount and percentage of assets or business activities vulnerable to climate-related physical risks.
The Group discloses physical-risk vulnerability across three lenses: (1) the underwriting-portfolio business-activity exposure expressed as Probable Maximum Loss (PML) under defined return-period × hazard combinations per FN-IN-450a.1; (2) investment-portfolio assets vulnerable to physical risks; and (3) operational PP&E vulnerable assets. The dominant vulnerability is in the underwriting portfolio. [IFRS S2.29(c); 30; FN-IN-450a.1]
(1) Underwriting business-activity exposure. Probable Maximum Loss.
| Hazard | 1-in-50 gross (CU) | 1-in-100 gross (CU) | 1-in-250 gross (CU) | |||
|---|---|---|---|---|---|---|
| SSP2-4.5 | SSP5-8.5 | SSP2-4.5 | SSP5-8.5 | SSP2-4.5 | SSP5-8.5 | |
| Tropical cyclone (incl. typhoon) | 0.62bn | 1.0bn | 0.95bn | 1.6bn | 1.4bn | 2.4bn |
| Flood (riverine + flash) | 0.38bn | 0.62bn | 0.55bn | 0.92bn | 0.84bn | 1.4bn |
| Bushfire | 0.31bn | 0.55bn | 0.49bn | 0.82bn | 0.74bn | 1.3bn |
| Severe convective storm (incl. hail) | 0.34bn | 0.45bn | 0.49bn | 0.62bn | 0.78bn | 1.0bn |
| East coast lows / mid-latitude lows | 0.18bn | 0.21bn | 0.27bn | 0.31bn | 0.42bn | 0.50bn |
| Drought (long-tail commercial) | 0.04bn | 0.07bn | 0.07bn | 0.11bn | 0.10bn | 0.16bn |
| Extreme heat (chronic) | 0.02bn | 0.05bn | 0.04bn | 0.08bn | 0.06bn | 0.12bn |
Net-of-reinsurance figures are after the strategic CU 2.8bn 5-year arrangement, whole-of-account quota share, and individual risk excess-of-loss treaties. PML disclosed at Group level; geographic disaggregation: AU 76% / NZ 24% of total gross PML. Climate-related scenarios used aligned with TCFD Supplemental Guidance for Insurance Companies. Baseline PML re-computed annually as part of the reinsurance-renewal cycle.
(2) Investment-portfolio physical-asset vulnerability. Under Disorderly / 2050, CU 1.4bn investment-portfolio carrying amount classified vulnerable to physical risks (7.8% of AUM). Under Hot House / 2050, CU 2.3bn / 12.8%. Vulnerability determined at investee asset coordinate using 1-in-100-year hazard return period under named scenario. Concentrated in AU corporate fixed income and global equities with operating sites in physical-risk-elevated geographies.
(3) Operational PP&E vulnerable assets. 5 of 38 corporate sites in elevated physical-risk regions: CU 18m PP&E carrying amount, equivalent to 6.4% of operational PP&E. Remediation underway through site adaptation capex and, where applicable, site relocation.
Illustrative figures. The Continuuiti Climate Risk service produces FN-IN-450a.1 PML triangulation, investment-portfolio physical-vulnerability mapping, and operational PP&E hazard exposure for any portfolio of locations using twelve physical hazards across five SSP-RCP scenarios and four time horizons.
Cohort findings: what reporters typically skip on Para 29(c)
Typically skipped (universal weak point). Para 29(c) is the most-skipped disclosure across the AU first wave. Even leading climate-disclosing general insurers do not quantify it; the typical pattern is a qualitative hedge that the Group’s assessment of potential financial impacts “continues to mature”. NZ FMA, KPMG AASB S2 First Impressions (FAST 30 tracker), PwC AASB S2 review, and Deloitte Wave 1 reviews have independently flagged the same gap. For insurance specifically, this is striking because the underlying actuarial output (PML triangulation under FN-IN-450a.1) already exists for reinsurance-renewal purposes; the gap is disclosure, not measurement.
What good looks like. PML triangulation per FN-IN-450a.1 (gross + net × 3 return periods × 7 hazards × multi-scenario); investment-portfolio asset-level vulnerability with carrying amount and percentage; operational PP&E exposure. Threshold, scenario, horizon, and adaptation treatment all explicit. Cross-reference to Para 14 reinsurance strategy and Para 22 resilience assessment.
Para 29(d). Climate-related opportunities: assets aligned with opportunities
The amount and percentage of assets or business activities aligned with climate-related opportunities. The opportunity-side counterpart to Para 29(b) and 29(c). Disclosure should pair the quantitative figure with revenue, capacity, or other operational metrics that contextualise the alignment claim.
Standard text (verbatim, IFRS S2 Para 29(d))
Climate-related opportunities. The amount and percentage of assets or business activities aligned with climate-related opportunities.
The Group discloses the amount and percentage of assets and business activities aligned with climate-related opportunities, across underwriting (low-carbon-tech and renewables) and investment portfolio (green bonds and climate-aligned assets). [IFRS S2.29(d); 30; FN-IN-410b.1; FN-IN-410b.2]
| Opportunity category | Amount (CU) | % of base | Source / metric |
|---|---|---|---|
| Investment-portfolio green bonds | 250m | 1.4% of AUM | Climate Action Plan Target 5 (floor CU 200m) |
| Underwriting.renewables (solar, wind, storage, hydro) | 62m | 0.4% of GWP | FN-IN-410b.1 net premiums written |
| Underwriting.EV and hybrid motor | 21m | 0.15% of GWP | FN-IN-410b.1 net premiums written |
| Underwriting.energy-efficiency and ESCO warranties | 12m | 0.09% of GWP | FN-IN-410b.1 net premiums written |
Product features incentivising adaptation (FN-IN-410b.2). The Group offers resilience-clause product features across home and commercial property lines: (i) sustainable-building discount for properties built or rebuilt to enhanced wind, flood, or fire-resistance standards (retail consumer brands); (ii) bushfire-zone hardening upgrade rebate at policy renewal (commercial property); (iii) flood-resilient build-back grant in major-event response (FY25 deployed in 4 events). Policy-count attribution to product features is not yet disclosed; tracking infrastructure is being built for FY27 disclosure.
Adaptation-services and customer engagement. The Group’s natural-hazard risk-reduction programme has supported 1.7m people in AU and NZ to take action to reduce their risk from natural hazards (Climate Action Plan Target 6, exceeded). Programme delivery via Insurance Council of Australia / ICNZ partnerships, customer-engagement campaigns, and direct grant programmes.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(d)
Typically skipped. Underwriting-side opportunity quantification. Insurers often disclose green-bond holdings and stop there; the FN-IN-410b.1 net-premium-written metric is the underwriting-side complement and is rarely surfaced. Also typically skipped: product-feature quantification. Many insurers describe resilience clauses but don’t disclose policy-count attribution or the financial impact of the feature.
What good looks like. Amount + percentage form for both investment portfolio and underwriting business activities; product-feature narrative with roadmap to quantification; customer-engagement programme metrics tied to Para 33-36 targets.
Para 29(e). Capital deployment toward climate-related risks and opportunities
The amount of capital expenditure, financing, or investment deployed toward climate-related risks and opportunities. Disclosure should disaggregate by category (mitigation, adaptation, opportunity) and ideally by sub-portfolio. The figure must reconcile with the entity’s strategy and decision-making disclosures (Para 14) and target-progress disclosures (Para 33-36).
Standard text (verbatim, IFRS S2 Para 29(e))
Capital deployment. The amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities.
The Group discloses capital deployed towards climate-related risks and opportunities, comprising operational decarbonisation capex, investment-portfolio reallocation flow, customer-side adaptation programme funding, and the strategic reinsurance arrangement (interpreted as climate-risk financing under Para 29(e)). [IFRS S2.29(e)]
| Capital category | Amount (CU) | Period | Purpose |
|---|---|---|---|
| Strategic reinsurance arrangement (natural-perils volatility) | 2.8bn | FY25 – FY30 (5 years) | Climate-risk capital management; reduces 1-in-100 PML net exposure (cross-reference Para 29(c)) |
| Operational decarbonisation capex | 35–50m | FY25 – FY30 cumulative | Renewable-electricity infrastructure (achieved FY25); low-emissions tool fleet transition; energy-efficiency upgrades |
| Investment-portfolio green-bond floor | 250m (current 1.4% of AUM) | FY25 standing commitment | Climate Action Plan Target 5 |
| Customer-side adaptation programme | ~28m | FY25 – FY30 cumulative | Climate Action Plan Target 6.partnerships, customer education, grants for natural-hazard risk reduction |
| CRR&O Process delivery | ~6m | FY25 – FY27 cumulative | Process establishment, divisional plan development, scenario-analysis tooling |
| External assurance (limited, ISAE 3000/3410) | ~2m per year | FY25 onwards | External limited assurance over GHG metrics |
Reinsurance under Para 29(e). The Group’s view is that the CU 2.8bn strategic reinsurance arrangement falls within Para 29(e) ‘financing… deployed towards climate-related risks’ because reinsurance is the primary capital-management lever for climate-related natural-perils volatility; the arrangement is multi-year committed financing structured around the climate-risk profile of the AU portfolio. The reinsurance premium (annual operating expense) is not reported under Para 29(e); the multi-year capacity commitment and structuring are.
Investment-portfolio reallocation flow. The Group’s investment-portfolio decarbonisation flow (incremental shift toward green-bond exposure plus reduction in carbon-intensive holdings) is reported under Para 29(b) trajectory and is not double-counted here.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(e)
Typically skipped. The explicit interpretive choice for reinsurance under Para 29(e). Most insurers describe the reinsurance program in Para 14 strategy but don’t link it to Para 29(e) capital deployment. Also typically skipped: distinction between annual premium (operating expense) and multi-year arrangement structure (capital deployment). The two are often conflated.
What good looks like. All capital categories tabulated; explicit interpretive note on reinsurance treatment; non-double-counting note connecting to Para 29(b) flow; multi-year commitment period named per bucket.
Para 29(f). Internal carbon prices
Disclose whether and how the entity applies an internal carbon price in decision-making (investment, transfer pricing, scenario analysis), and the per-tonne price used. Disclosure should distinguish between prices applied to operational decisions and prices used in strategic and scenario contexts. Sectors with material own-emissions exposure typically apply different prices for different decision contexts.
Standard text (verbatim, IFRS S2 Para 29(f))
Internal carbon prices. The entity shall disclose:
(i) an explanation of whether and how the entity is applying a carbon price in decision-making (for example, investment decisions, transfer pricing and scenario analysis);
(ii) the price for each metric tonne of greenhouse gas emissions the entity uses to assess the costs of its greenhouse gas emissions.
The Group applies an internal carbon price to support climate-related decision-making in two areas: investment-portfolio screening and operational capex prioritisation. Internal carbon pricing is not applied to insurance underwriting decisions because the underwriting decision logic is dominated by short-tenor risk-transfer pricing rather than long-tenor capital allocation. [IFRS S2.29(f)]
(i) Whether and how applied (Para 29(f)(i)).
| Application area | Carbon price (CU/tCO2e) | Purpose |
|---|---|---|
| Investment-portfolio screening (equity + corporate fixed income) | 120 | Shadow price applied in investee-level analysis to inform allocation decisions and engagement priorities; aligned with NGFS Phase IV regulated-jurisdictions trajectory by 2030 |
| Operational capex (above CU 1m) | 120 | Shadow price added to lifecycle-cost analysis for property, energy, fleet, and IT-infrastructure capital projects; intended to bias decisions toward lower-emissions options |
| Insurance underwriting decisions | n/a | Not applied. Underwriting pricing is risk-of-loss based; carbon-intensity of insured operations is not a direct input to premium pricing |
| Reinsurance treaty negotiation | n/a | Not applied. Treaty pricing reflects climate-driven peril cost trajectories rather than counterparty carbon emissions |
(ii) The price (Para 29(f)(ii)). CU 120 per tonne CO2 equivalent applied across both investment-portfolio screening and operational capex. The price is set with reference to NGFS Phase IV regulated-jurisdictions central-case carbon-price trajectory by 2030 and is reviewed annually as part of the CRR&O Process refresh. Prior to FY25 the Group did not formally apply an internal carbon price; the FY25 introduction is itself a Para 25(a)(vi) process change.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(f)
Typically skipped. Explicit statement that carbon pricing is not applied to underwriting. Insurer disclosures often skip 29(f) entirely because it does not fit the operating model; the better position is to explain why. Also skipped: distinction between shadow-price application areas (investment vs operational vs underwriting).
What good looks like. Explicit yes/no per application area; named price; basis for the price; review cadence; cross-reference to Para 25 process change.
Para 29(g). Remuneration: climate-linked executive compensation
Disclose whether and how climate-related considerations factor into executive remuneration, and the percentage of executive compensation in the current reporting period that is climate-linked. The percentage should reconcile with the climate KPIs disclosed under Para 33-36 and the governance-oversight disclosures under Para 6(a)(v).
Standard text (verbatim, IFRS S2 Para 29(g))
Remuneration. The entity shall disclose:
(i) a description of whether and how climate-related considerations are factored into executive remuneration (see also paragraph 6(a)(v));
(ii) the percentage of executive management remuneration recognised in the current period that is linked to climate-related considerations.
Climate-related considerations are factored into executive remuneration through the Group Balanced Scorecard (BSC) and Executive Divisional Balanced Scorecards. [IFRS S2.29(g); 6(a)(v)]
(i) Whether and how (Para 29(g)(i)). Executive remuneration comprises fixed remuneration, Short-Term Incentive (STI) tied to the Group Balanced Scorecard, and Long-Term Incentive (LTI) tied to long-term shareholder return. Climate-related performance has been factored into the STI through (a) the Group Balanced Scorecard climate weighting, and (b) Executive Divisional BSC climate goals tailored to each Divisional remit (Underwriting, Claims, Investments, Risk, Operations).
(ii) Percentage linked (Para 29(g)(ii)).
| Period | Climate weight in Group BSC (STI) | Divisional BSC climate goals | Mechanism |
|---|---|---|---|
| FY24 | 5% | Limited; CEO and CFO only | GHG emissions reduction measure (Scope 1+2) |
| FY25 (current) | 5% | Limited; CEO and CFO only | GHG emissions reduction measure (Scope 1+2 plus limited Scope 3) |
| FY26 (forward) | 0% (Group BSC removed) | Broader integration; relevant Executives across Divisions | Multiple climate goals tailored per Divisional remit |
The shift from a single Group BSC climate measure to broader Divisional BSC integration is a deliberate design change to drive deeper climate accountability through line-management remuneration rather than concentrating it in CEO and CFO Group BSC weighting. The Group expects the effective climate-related percentage of total executive remuneration to rise net-net under the new design, although disclosure granularity will improve only after FY26 reporting.
The People & Remuneration Committee makes recommendations to the Board on the inclusion of climate-related measures in executive incentive plans. The Board approves the Group BSC and reviews Executive Divisional BSC outcomes annually.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(g)
Typically skipped. Divisional BSC granularity. Insurer disclosures often report only Group BSC weighting and not the divisional integration that moves the actual incentive needle. Also skipped: directional change disclosure (FY24 → FY25 → FY26). Year-on-year change tells the reader whether the architecture is firming or loosening.
What good looks like. Group BSC plus Divisional BSC summary; year-on-year trajectory; rationale for design choices; cross-reference to Para 33-36 targets and Para 6(a)(v) oversight.
Para 32. Industry-based metrics
Disclose industry-based metrics associated with the entity’s business model and activities. The standard refers entities to the SASB Industry-Based Guidance (IBG) on implementing IFRS S2 — applicability is per industry. The IBG metrics complement (not replace) the cross-industry Para 29 disclosures; both must be reconciled where they overlap.
Standard text (verbatim, IFRS S2 Para 32)
An entity shall disclose industry-based metrics that are associated with one or more particular business models, activities or other common features that characterise participation in an industry. In determining the industry-based metrics that the entity discloses, the entity shall refer to and consider the applicability of the industry-based metrics associated with disclosure topics described in the Industry-based Guidance on Implementing IFRS S2.
The Group discloses industry-based metrics aligned with the IFRS S2 Industry-based Guidance for Insurance (FN-IN, vol-17). The metrics are organised into three disclosure topics. [IFRS S2.32; IBG vol-17 FN-IN]
FN-IN-410a.2 Approach to incorporation of ESG factors in investment management. The Group’s approach to ESG incorporation is described in §1 Climate-related strategy (Investment Portfolio) of the Sustainability Report. Approaches used include negative screening (carbon-intensive sectors, controversial weapons), best-in-class screening (top-quartile ESG performers in equity holdings), and ESG integration (systematic inclusion of climate-and-sustainability factors in investment analysis). External fund managers are subject to ESG due-diligence and ongoing oversight. Asset-class disaggregation: equities (full ESG integration); corporate fixed income (issuer-level ESG screening); government fixed income (sovereign ESG indicators); cash (limited applicability).
FN-IN-450a.1. Probable Maximum Loss (PML) of insured products from weather-related natural catastrophes. Disclosed under Para 29(c) above with full hazard × return-period × gross/net triangulation. Climate-related scenarios used align with TCFD Supplemental Guidance for Insurance Companies (NGFS Phase IV + AEMO + CSIRO + ICNZ).
FN-IN-450a.2 Total monetary losses attributable to insurance pay-outs from natural catastrophes.
| Event type | FY25 modelled losses (CU m) | FY25 non-modelled losses (CU m) | Gross | Net of reinsurance |
|---|---|---|---|---|
| Tropical cyclone (incl. ex-TC Alfred March 2025) | 620 | n/a | 620 | 185 |
| Severe convective storm and hail | n/a | 180 | 180 | 54 |
| Flood (riverine and flash) | n/a | 240 | 240 | 72 |
| Bushfire | n/a | 40 | 40 | 16 |
| East coast lows / mid-latitude lows | 120 | n/a | 120 | 36 |
| Drought | n/a | n/a | n/a | n/a |
| Extreme heat | n/a | n/a | n/a | n/a |
| Total natural-catastrophe claims (FY25) | 740 | 460 | 1.2bn | 363 |
Geographic split: Australia 88%, New Zealand 12%. Modelled events are those analysed using the Group’s catastrophic risk models (TC and major mid-latitude lows); non-modelled events are smaller-scale or high-frequency-low-severity perils tracked through aggregate-claim experience. Benefits and claims incurred reported in accordance with IFRS 17. [FN-IN-450a.2; IFRS 17]
Note to FN-IN-450a.2. The Group’s reinsurance program absorbs ~70% of gross natural-catastrophe claims through the strategic 5-year arrangement, whole-of-account quota share, and individual-risk excess-of-loss treaties. Reinsurance program cost has risen 22% over the past 3 years, reflecting market repricing of climate-driven peril risk.
FN-IN-450a.3 Approach to incorporation of environmental risks into underwriting and entity-wide risk management. The Group’s approach to incorporating environmental risks (TCFD-defined three classes: physical, transition, liability) into underwriting and entity-wide risk management is described in §3 Climate-related risk management of the Sustainability Report. Key elements: probabilistic CAT-modelling integration; pricing for individual contracts using risk-of-loss-based methodology with hazard-zone overlay; client and cedent selection; resilience-incentive policy clauses (sustainable-building discounts, weather-resiliency upgrades); alternative risk transfer (catastrophe bonds, weather derivatives); and integration into the COSO ERM framework via the Group RMFS. The Group’s three-class TCFD framing (physical / transition / liability) is consistent with the FN-IN-450a.3 specification.
FN-IN-000.A activity metric. Policies in force by segment.
| Segment | Policies in force (millions) |
|---|---|
| Property & casualty (motor, home, commercial) | 2.4 |
| Life | 0 |
| Assumed reinsurance | 0 |
| Total | 2.4 |
Illustrative figures based on IBG vol-17 FN-IN metric specifications. PML triangulation per FN-IN-450a.1 is in the Para 29(c) cell.
Cohort findings: what reporters typically skip on Para 32
Typically skipped. Full IBG metric set. Insurers often disclose PML (FN-IN-450a.1) and stop there; FN-IN-450a.2 modelled-vs-non-modelled split and FN-IN-450a.3 underwriting-integration narrative are equally required by Para 32 cross-reference. Also typically skipped: the modelled vs non-modelled split itself, where most disclosures lump natural-catastrophe losses without showing which were modelled.
What good looks like. Full FN-IN spine with all 7 metrics covered; modelled / non-modelled split; reinsurance program cost trajectory; FN-IN-000.A activity metric; IFRS 17 cross-reference; TCFD three-class framing made explicit.
Para 33–36. Climate-related targets: quantitative and qualitative
Disclose the quantitative and qualitative climate-related targets set to monitor strategic progress, including any targets required by law or regulation. For each target: the metric, objective, scope, period, base, milestones, absolute-vs-intensity classification, and how the latest international climate agreement informed it. Performance against targets must be disclosed; for GHG targets, gases covered, scopes, gross-vs-net classification, and any planned use of carbon credits with verification scheme detail.
Standard text (verbatim, IFRS S2 Para 33–36)
An entity shall disclose the quantitative and qualitative climate-related targets it has set to monitor progress towards achieving its strategic goals, and any targets it is required to meet by law or regulation, including any greenhouse gas emissions targets. For each target, the entity shall disclose:
(a) the metric used to set the target;
(b) the objective of the target (for example, mitigation, adaptation or conformance with science-based initiatives);
(c) the part of the entity to which the target applies;
(d) the period over which the target applies;
(e) the base period from which progress is measured;
(f) any milestones and interim targets;
(g) if the target is quantitative, whether it is an absolute target or an intensity target;
(h) how the latest international agreement on climate change, including jurisdictional commitments that arise from that agreement, has informed the target.
An entity shall disclose information about its approach to setting and reviewing each target, and how it monitors progress against each target, including:
(a) whether the target and the methodology for setting the target has been validated by a third party;
(b) the entity’s processes for reviewing the target;
(c) the metrics used to monitor progress towards reaching the target;
(d) any revisions to the target and an explanation for those revisions.
An entity shall disclose information about its performance against each climate-related target and an analysis of trends or changes in the entity’s performance.
For each greenhouse gas emissions target the entity shall disclose:
(a) which greenhouse gases are covered by the target;
(b) whether Scope 1, Scope 2 or Scope 3 greenhouse gas emissions are covered by the target;
(c) whether the target is a gross greenhouse gas emissions target or net greenhouse gas emissions target. If the entity discloses a net greenhouse gas emissions target, the entity is also required to separately disclose its associated gross greenhouse gas emissions target;
(d) whether the target was derived using a sectoral decarbonisation approach;
(e) the entity’s planned use of carbon credits to offset greenhouse gas emissions to achieve any net greenhouse gas emissions target, including
(i) the extent to which, and how, achieving any net greenhouse gas emissions target relies on the use of carbon credits;
(ii) which third-party scheme(s) will verify or certify the carbon credits;
(iii) the type of carbon credit, including whether the underlying offset will be nature-based or based on technological carbon removals, and whether the underlying offset is achieved through carbon reduction or removal;
(iv) any other factors necessary for users to understand the credibility and integrity of the carbon credits the entity plans to use.
The Group has set the following climate-related targets per the FY24 Climate Action Plan (CAP, August 2024). Six targets across operations, value chain, and customer-side adaptation. [IFRS S2.33-36]
| Target | Metric | Objective | Scope | Period | Base year | Milestones | Absolute / intensity | Paris-aligned? |
|---|---|---|---|---|---|---|---|---|
| Target 1: Net Zero Scope 1+2 | tCO2e | Mitigation | Group operations | FY30 | FY24 | FY26 -50%; FY28 -75% | Absolute (net zero) | 1.5°C aligned |
| Target 1.1: 100% renewable electricity | % | Mitigation | Group operations (AU+NZ) | FY25 (achieved) | n/a | FY24 88%; FY25 100% | Absolute (100%) | Yes |
| Target 1.2: 100% low-emissions tool fleet | % | Mitigation | Group operations | FY30 | n/a | FY27 78%; FY29 92% | Absolute (100%) | n/a |
| Target 2: -50% upstream operational Scope 3 | tCO2e | Mitigation | Group operations (limited Scope 3 cats 1, 3, 5, 6, 7) | FY30 | FY24 | FY26 -18%; FY28 -32% | Absolute (-50%) | 1.5°C aligned |
| Target 3: Enterprise climate awareness campaign | Status | Mitigation enabler | Group employee base | FY25 (delivered) | n/a | FY24 design; FY25 launch | Absolute (delivery) | n/a |
| Target 4: Investment portfolio carbon reduction | tCO2e and tCO2e/$m AUM | Mitigation | Investment portfolio (AU equities ASX200 ex-self; global equities MSCI World) | FY25 (-25%) / FY30 (-50%) | FY20 | FY25 -25% (delivered AU -69%, global -60%) | Intensity (-50%) | n/a |
| Target 5: Maintain green bond investments | CU million | Opportunity | Investment portfolio | FY25 (achieved) standing | n/a | FY24 floor met (CU 215m); FY25 floor met (CU 256m) | Absolute (CU 200m floor) | n/a |
| Target 6: Customer natural-hazard risk reduction | People supported (count) | Adaptation | AU+NZ retail customer base | FY25 (delivered 1.7m) | FY21 | FY23 0.8m; FY24 1.3m; FY25 1.7m | Absolute (1.0m target) | n/a |
Para 34 validation, review, monitoring, revisions. Operational and Scope 3 emissions targets methodology has not yet been validated by SBTi (validation in progress). Targets are reviewed annually by the Sustainability Committee and ratified by the Board; CAP is republished alongside the annual Sustainability Report. The Group’s external auditor provides limited assurance over GHG metrics under ISAE 3000/3410. Methodology revisions in the current period: NZ MfE 2024 emission factor update applied with one-year-arrears restatement; Target 4 baseline (FY20) confirmed in the current cycle.
Para 35 performance.
| Target | FY25 | FY24 | FY23 | Base year | Status |
|---|---|---|---|---|---|
| Target 1: Net Zero Scope 1+2 by FY30 | 12,199 tCO2e (-38%) | 19,710 tCO2e (baseline) | 22,500 tCO2e (pre-baseline) | 19,710 tCO2e (FY24) | On track |
| Target 1.1: 100% renewable electricity by FY25 | 100% | 88% | 65% | n/a | Achieved FY25 |
| Target 1.2: 100% low-emissions tool fleet by FY30 | 63% | 45% | 28% | n/a | On track for FY30 |
| Target 2: -50% upstream Scope 3 by FY30 | -9% (91% of FY24) | baseline | n/a (pre-baseline) | FY24 baseline | On track for FY30 |
| Target 3: Enterprise climate awareness campaign | Delivered May 2025 | Programme designed | Concept stage | n/a | Achieved FY25 |
| Target 4: Investment portfolio carbon reduction (intensity, base FY20) | AU -69%, global -60% | AU -55%, global -48% | AU -38%, global -32% | FY20 baseline | Both populations exceeded ahead of schedule |
| Target 5: Maintain green bond investments (CU 200m floor) | CU 256m | CU 215m | CU 195m (acquired through FY24) | n/a | Maintained above floor |
| Target 6: 1m people supported in NatHazard reduction (base FY21) | 1.7m | 1.3m | 0.8m | 0.1m (FY21) | Exceeded ahead of schedule |
Para 36 GHG-target detail. All seven Kyoto-Protocol gases (CO2, CH4, N2O, HFCs, PFCs, NF3, SF6) included in measurement. All GHG targets are gross. Carbon credits not used in the FY25 reporting period and not planned for use against operational targets through FY30. The Group does not apply a sectoral decarbonisation approach (whole-Group target). Para 36(d) sectoral decarbonisation approach: not used. Para 36(e) carbon credits: Target 1 may use carbon-removal offsets to cover residual emissions post-FY30; offsets will be third-party verified per Verra or Gold Standard; nature-based vs technology-based mix to be determined.
Illustrative target set.
Cohort findings: what reporters typically skip on Para 33–36
Typically skipped. Sector-distinctive adaptation-side targets like the 1m-people NatHazard reduction. Most insurer disclosures focus on emissions targets and treat the customer-side programme as a community-engagement metric rather than a Para 33-36 target. Also typically skipped: Para 36(c) gross-vs-net disclosure for each target. Insurers often report ‘net zero by 2050’ without disclosing whether the headline is gross or net.
What good looks like. Target table covering all 8 Para 33 attributes per target; performance against base year; explicit gross-vs-net per Para 36(c); validation framework; carbon-credit policy with named verification scheme; adaptation-side non-emissions target surfaced.
Commentary