According to the Office for National Statistics, there are 147,920 UK companies with turnover between £2m and £20m. That’s only the lower half of the mid-market. Add the firms between £20m and £100m, and you have a vast slice of the economy that insurers underwrite, reinsure and invest in every day.
Almost none of it shows up clearly in a risk model. For insurers, that isn’t a data quirk. It’s an exposure problem.
Where Mandatory Disclosure Stops
UK mandatory climate-related financial disclosure only applies to companies with more than 500 employees and £500m turnover. Below that line, disclosure is voluntary, inconsistent and scattered.
Break the lower band down and the scale becomes clear:
- 55,020 companies with turnover of £2m–£5m
- 92,900 companies with turnover of £5m–£20m
- Thousands more between £20m and £100m
These are the policyholders, suppliers and counterparties behind commercial lines, supply chains and investment portfolios. Together, they make up the Data Gap.
The Information Exists. It Just Isn’t Streamlined.
Mid-market companies do share how they operate. It sits in website statements, policy documents, certifications and annual reports. But it is fragmented across formats and sources, and it rarely reaches an underwriting file in a form anyone can use.
So risk teams fall back on sector averages and proxies. That means:
- Two very different businesses in the same sector look identical on paper
- Resilience strengths and weaknesses go unpriced
- ORSA and Solvency II assessments lean on assumptions rather than evidence
- Frameworks such as TNFD ask questions the data cannot yet answer
None of this is a failing of the models. They were built for companies that publish structured data, and the mid-market was never part of that design.
What Better Mid-Market Evidence Looks Like
Closing the Data Gap doesn’t mean asking every company to fill in another questionnaire. Survey fatigue is already a recurring problem for mid-market firms.
The better route starts with what companies already publish and makes it comparable. Benchmarked against peers of a similar size, a company’s own reported practices tell an underwriter far more than a modelled stand-in. Knowing what each indicator rests on, and how strong the underlying disclosure is, makes it defensible.
What This Means for Insurers
The mid-market isn’t a niche. It is where a large share of UK commercial risk actually sits. Seeing it clearly means sharper pricing, more defensible capital assessments and fewer surprises in the book.
About Public Disclosure Analysis
The Disruption House is a Risk & Resilience Intelligence business closing the Data Gap on UK mid-market companies. Our public disclosure analysis assesses what companies already publish, from websites to policies, reports and certifications, against 120 metrics aligned with international frameworks.
Every company is benchmarked against its sector, industry and revenue group, with evidence types and disclosure strength visible for each result. Results are delivered through dashboards or via API, with zero or limited engagement needed from the companies themselves.
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Click Contact Us to run public disclosure analysis on a sample of your portfolio and see what the evidence says about the companies your models currently can’t see.
