A single benchmark for sustainability: how insurers are building uniform ESG standards
ESG figures from organisations in the same sector are often difficult to compare, because they use different calculation methods. The Dutch insurance sector decided to do something about this: since last year, insurers have been building new standards together, organised by the Dutch Association of Insurers with support from Deloitte. This helps both insurers and their customers make better, more sustainable choices.
The challenge
Be able to compare reports with each other
Until recently, an old Volvo V50 was given an orange CO₂ score by one insurer and a red one by another. For a 2019 Mercedes C-Class, the differences in the so-called insurance-associated emissions varied even further: one insurer calculated with 88 kilos of CO₂ emissions, the other with 237 kilos. And that while these kinds of figures are among the simpler CSRD calculations.
The Corporate Sustainability Reporting Directive (CSRD) forces large companies to report transparently on sustainability. But insurers themselves do not only want to know the impact of their portfolios on people and the environment. They also want to be able to compare the scores well. After all, insurance portfolios touch on many themes that affect climate change. "Take car ownership, for example or the way we make our real estate more sustainable or deal with damage repair," says Martijn Minkenberg, who is the ESG standards programme leader from the Dutch Association of Insurers. "That's why most insurers are quite ambitious in this area. They themselves want to be climate neutral by 2050 and are taking various measures to contribute to the national and international reduction of CO₂ emissions. In order to limit future damage from climate change or even better: to prevent it."
Good substantive guidance requires both broad and deep expertise in insurance, emissions reporting and accountancy. This combination of expertise is ensured in this project.
Jan-Jacob Blussé van Oud-Alblas
The approach
Constructive, meticulous conversations
Since last year, insurers have been working on the development of ESG standards, organised by the Dutch Association of Insurers with support from Deloitte. “Good substantive guidance requires both broad and deep expertise,” says Jan Jacob Blussé, project leader from Deloitte. “Broad, because it concerns cars, houses, and property development. Deep, because it concerns building insurance clauses, underwriting, and climate mitigation. This combination of expertise is ensured in this project.”
The project started in early 2025 with discussions on ESG standards for the private car insurance and business insurance sectors. These standards have now been published, as have standards for private housing and road transport. Among other things, work is now being done on a standard for measuring climate adaptation. The programme is therefore in its third phase. This is striking at a time when the European Parliament has considerably weakened the CSRD and sustainability regulations are under political pressure. Minkenberg: "Insurers in particular want to be fully committed to the world of tomorrow. To become climate neutral, good, comparable data is needed."
The Deloitte team, which combines industry knowledge, sustainability, data and reporting, guides these sessions as a neutral party. They prepare the sessions, monitor the method, bring in additional expertise where useful and keep up the pace. Blussé: "We have brought together the product experts in one consultation structure, the reporting experts in another and the sustainability officers in yet another. Because we let people of the same blood type talk to each other, we keep the meetings compact and they understand each other quickly. We ensure that matters that another group has to think about or about which fundamental choices have to be made end up with the right group."
Minkenberg: "Because the sessions are supervised by someone from outside our sector, the conversations are effective and the outcome is really something from the collective. Also because the required expertise is considerable. I do not think you can do that very well without external support. Also, preparing and recording everything in a relevant way is a lot of work."
Even with the more difficult choices, the presence of a neutral knowledge-intensive party is pleasant, Minkenberg believes. Blussé: "Every insurer has its own approach. One person counts a car that was only added to the portfolio in May for the entire year, the other looks at how many months a car is part of the portfolio. But for an ESG standard, you have to have an opinion on it as a collective and it also has to be practically feasible. So these are quite complicated conversations, in which the participants have to break free from what they are used to doing. Fortunately, this has always worked very well so far, because the starting point is always to arrive at the best representation of reality."
The solution
A sustainability reporting toolkit
The members of the Dutch Association of Insurers have access to the ESG-CSRD Toolkit developed by the association, which contains the currently approved joint sector standards. The toolkit also describes a logical working method, containing relevant data attributes, measurement points, calculation methods, data sources and a blueprint of the data structure. In addition, it contains practical explanations, with Dutch definitions, according to the Insurance Reporting Guidance ESG (NL-IRGE). Insurers can include the standard text blocks in the toolkit directly in their annual report.
Dutch insurers are leading the way internationally in the development of the standards. There have been international frameworks such as PCAF for the financial sector for some time, but they are much more general and at a higher level of abstraction. The Dutch approach goes a step further: there are sector-specific standards for calculating the footprint. For all situations that may occur in a portfolio, agreements have been made about how you report on this as an insurer.
There is already a lot of interest from foreign insurers and international umbrella organisations, says Minkenberg. "The standards align with existing international frameworks, so parts can be copied. Although of course each country will still have to go through its own process."
Reporting is ultimately a means. If you measure well, you can steer better. Clear figures on climate impact make climate risks transparent and therefore manageable.
Martijn Minkenberg
The impact
Making more sustainable choices
Insurers benefit from the toolkit because they do not have to reinvent the wheel independently. Defining and reporting CSRD standards takes a huge amount of work. By doing this together, the sector not only saves time, but also improves the quality of the standards. The fact that the programme has now gone through several phases also proves the scalability of the approach: the working method with sector tables, a validation committee and a standardised toolkit can be reuse for each new insurance theme. One of the insurers who cooperated said: "Normally you lock yourself up for a few months to work on a report. Then you come out with a ream of paper and then you just hope that it is in line with what your competitors have done and that your accountant agrees to it. Now you go through the steps from your toolkit that you know other insurers are also using." Minkenberg: "What also helps is that every step is well substantiated and explainable and that also makes the accountant happy."
This method also provides advantages for customers and regulators. If insurer An and insurer B calculate the same portfolio in the same way, a difference in outcome really says something. This helps to combat greenwashing: if you follow the standard, you can get a certain negative impact to the surface and take action on it.
According to Minkenberg, the real impact is that insurers will ultimately be able to manage better and smarter with this standard. "Reporting is ultimately a means. Clear figures on climate impact make climate risks transparent and therefore manageable. They help both insurers themselves and their customers to make better, more sustainable choices. And that fits seamlessly with the great ambitions of our sector."
For more information about the NL-IRGE standards, visit the website of the Dutch Association of Insurers. Do you want to know what a similar approach can do for your sector? Please contact Jan-Jacob Blussé.
