Imagine a regulator, reinsurer or client asked you a question tomorrow. Across the companies you insure or source from, how many could evidence the policies and practices they say they have?
For most portfolios, the answer is that nobody knows. The evidence often exists, but it is fragmented across websites, policy PDFs and annual reports that no one has mapped against current requirements.
That gap is a risk exposure in its own right.
The Rules Narrowed. The Evidence Expectations Didn’t.
According to Latham & Watkins, the EU’s Omnibus I Directive was published in the Official Journal on 26 February 2026, raising the CSDDD threshold to companies with more than 5,000 employees and over €1.5 billion in turnover. CSRD has narrowed in a similar way.
On paper, most mid-market companies have stepped outside direct scope. In practice, the expectations have moved rather than disappeared:
- In-scope corporates still need credible information on their value chains
- Insurers still face supervisory expectations on climate risk under PRA SS5/25, alongside ORSA and Solvency II
- Underwriters still carry the risk of counterparties whose practices they cannot verify
The question is no longer whether a mid-market company must report. It is whether you can show what you relied on.
What a Readiness Snapshot Measures
A useful snapshot maps each company against the evidence that current frameworks ask for. Questions include:
- Is there a published climate or environmental policy?
- Is there a modern slavery statement or supplier code of conduct?
- Are emissions figures reported by the company, or only estimated?
- Are relevant certifications and ISO standards held and current?
- Is there governance oversight of these risks?
Each answer falls into one of three groups: evidenced by the company’s own reported data, partially evidenced, or reliant on proxy and sector-average estimates.
Why the Split Matters
Proxy data has its place. It fills coverage gaps and supports portfolio-level modelling. What it cannot do is evidence that a specific company meets a specific expectation.
A company’s own disclosures, sustainability reports and quantitative figures can. That is why disclosure strength, not a headline score, determines regulatory readiness.
What This Means for Insurers and Corporates
Regulatory readiness is a risk question before it is a reporting question. The exposure sits wherever your view of a counterparty rests on estimates rather than evidence.
A snapshot shows you where that line falls across your book. It tells you which companies are well evidenced, which need follow-up, and where engagement or pricing should reflect uncertainty. It also gives you a defensible trail when supervisors or clients ask how you reached your view.
About Public Disclosure Analysis
TDH’s public disclosure analysis assesses UK mid-market companies against a 120-metric framework, using what companies already publish: website disclosures, policy documents, sustainability reports, certifications and quantitative data. Results are benchmarked by sector, industry and revenue group across 11 sectors and 77 industries, can be mapped to regulatory frameworks, and are delivered via API or flat file.
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