Ask ten underwriters, portfolio risk leads, or supply chain teams which sustainability
framework they report against, and you’ll likely get ten different answers. SFDR, TNFD,
ORSA, an internal risk taxonomy, a client’s own transition plan — the categories rarely
match, and the underlying data almost never does either.
That mismatch is the real barrier to defensible risk pricing and portfolio oversight. Not a
lack of data, but a lack of structure that lets data move between frameworks.
According to the UK’s Transition Plan Taskforce (TPT), consistent, comparable
disclosure structures are essential if financial institutions are going to assess transition
risk credibly across their portfolios. The challenge is that most private companies don’t
publish against any single template — so every institution ends up building its own.
The Problem With One-Size-Fits-All Data
Insurers, reinsurers, and corporates need sustainability and resilience data that speaks
their internal language, not a generic scorecard. But most disclosure data arrives:
• Survey-driven and inconsistent between counterparties
• Structured around someone else’s categories, not yours
• Impossible to benchmark at portfolio or supplier level
• Disconnected from the frameworks that actually drive decisions — SFDR, TNFD,
ORSA
The result: risk and compliance teams spend more time reconciling formats than
assessing exposure.
What Happened When We Mapped 120 Metrics Onto Seven Categories
We recently tested this problem directly. TDH’s public disclosure analysis — a 120-
metric, SASB-aligned framework spanning 11 sectors and 77 industries — was mapped
against a bank’s own climate transition plan, which organised its reporting
requirements into seven distinct categories.
Every one of the 120 metrics slotted into the bank’s existing structure without a gap.
Nothing had to be invented, and nothing was left over.
That’s the point of the exercise: the underlying data was never the constraint. The
constraint was always translation.
An Ecosystem of Data, Not a Fixed Template
Public disclosure analysis isn’t built around one output format. It’s a full data set sitting
behind the scenes, ready to be remapped:
• Against regulatory frameworks like SFDR, TNFD, or ORSA
• Against value chain or supplier code of conduct requirements
• Against an insurer’s own risk taxonomy or capital model
• Against a bespoke dashboard built for a specific portfolio or client
Because scoring runs at the individual metric level — company, sector, industry, and
revenue-group benchmarks included — any category structure a team already uses can
simply be populated, rather than rebuilt from scratch.
What This Means for Insurers and Corporates
Bespoke doesn’t mean bespoke data collection every time. It means bespoke
organisation of data that already exists, verified and benchmarked, ready to sit inside
whatever framework your risk, underwriting, or compliance function already runs on.
Explore Public Disclosure Analysis
If your team is reconciling disclosure formats instead of assessing risk, it’s worth seeing
how your own categories could be populated directly. Get in touch with TDH to map
public disclosure analysis against your framework.
