An underwriter sits down to price a commercial policy for a mid-market manufacturing
business. They have the financials. They have the claims history. What they don’t have
— and almost certainly can’t get — is any structured data on how that business actually
operates: its supply chain dependencies, its environmental exposures, its governance
practices, or its operational resilience under stress.
They make a judgement call. They always do. And in doing so, they absorb a category of
risk they cannot see, quantify or price with any real confidence.
The Data That Doesn’t Exist
The commercial insurance market prices billions of pounds of risk every year on
companies that publish almost no non-financial data. Unlike large listed firms, private
mid-market businesses — typically those with turnover between £2m and £100m —
have no obligation to disclose sustainability, resilience or operational risk information.
Most don’t. And the information insurers do collect, through proposal forms and
periodic surveys, is inconsistent, self-reported and not comparable across a portfolio.
This creates a structural problem. Underwriting models are only as good as the data
that feeds them. When non-financial risk factors — climate transition exposure, supply
chain concentration, environmental liability, governance quality — are absent from the
picture, they don’t disappear from the risk. They simply become invisible to the insurer
until a claim arrives.
What Good Non-Financial Data Actually Enables
The consequences of this data gap run deeper than individual pricing decisions. At
portfolio level, insurers cannot benchmark their exposures, identify concentrations, or
build the defensible risk models required by frameworks like ORSA, SFDR and TNFD.
Regulatory pressure in this area is only increasing.
Consistent, comparable non-financial data on insured counterparties would change
this across several dimensions:
• Underwriters could differentiate risk within a sector rather than relying on sector
averages
• Portfolio risk teams could identify concentrations of climate transition or
physical risk before they crystallise
• Actuarial teams could build more defensible solvency models
• Regulatory disclosures could reflect actual portfolio data rather than estimates
How TDH Data Closes the Gap
TDH data addresses this directly. Built on a 120-metric framework aligned with
international sustainability standards — TDH data profiles private mid-market
companies using scalable, automated analysis of public disclosures. This includes
website disclosures, sustainability reports, policy documentation and certifications,
assessed against a sector baseline of analyst-curated, double-verified company data.
Where quantitative data exists, it is captured. Where it doesn’t, nearest-neighbour
modelling produces reliable estimates — clearly labelled and benchmarked against
sector, industry and revenue group averages. The result is consistent, decision-ready
risk intelligence on companies that have the right not to disclose — and typically
exercise it.
Pricing Risk with Your Eyes Open
The non-financial data gap in commercial insurance is not a new problem. What is new
is the regulatory and competitive pressure to solve it — and the availability of tools that
can do so at scale, without relying on counterparty participation.
Explore TDH Data for Insurance
Find out how TDH data is helping insurers build more confident underwriting and more
defensible risk frameworks. Get in touch with The Disruption House to learn more.
