Picture the UK economy as a map that lights up wherever a company’s risk profile is clear to insurers. The largest businesses glow brightly, because they sit inside mandatory climate-related financial disclosure, which only applies above 500 employees and £500m turnover.
Below that line, the map goes dim. Not because the companies are dark, but because nothing is joining up what they publish.
That dim zone is the £2m–£100m mid-market, and it is far bigger than many assume.
How Big Is the Blind Spot?
According to the ONS, there are 147,920 UK companies with turnover between £2m and £20m. That is the lower band alone, before counting a single business between £20m and £100m.
Break it down and the scale gets sharper:
- 55,020 companies turn over £2m–£5m
- 92,900 companies turn over £5m–£20m
All of them fall below the mandatory climate-related financial disclosure threshold
These are the manufacturers, logistics firms, care providers and hospitality groups that fill commercial books and sit in corporate supply chains. For many insurers, they are the portfolio.
Why Risk Models Struggle to See Them
This isn’t a lack of information. Mid-market companies publish a great deal: policies on their websites, sustainability reports, certifications, energy figures and governance statements.
The problem is structure. That information is scattered across formats, locations and levels of detail, so it rarely reaches an underwriting model in a form that can be compared. That is the Data Gap.
When the evidence can’t be consolidated, models fall back on sector averages. Every care home looks like the average care home, and every logistics firm inherits the risk profile of its peers. The resilient operator and the exposed one end up priced the same, and neither the insurer nor the client can see why.
What Changes When the Evidence Is Structured
TDH’s public disclosure analysis turns what mid-market companies already publish into consistent, comparable risk and resilience intelligence. It scores each company against a 120-metric framework aligned to SASB, covering 11 sectors and 77 industries.
Every sector is anchored by a baseline of double-verified data on at least 1,000 companies. Where a company’s own reported evidence is thin, nearest-neighbour similarity analysis fills the gap with a best-fit estimate drawn from the most similar companies, rather than a broad sector average.
For insurers, that means sharper underwriting on individual risks, portfolio views that reflect real variation, and stronger evidence for ORSA and supervisory conversations.
What This Means for Insurers
The mid-market isn’t invisible. It is unstructured, and that is a solvable problem, because the evidence already exists in the public domain.
The insurers who close the Data Gap first will price this segment on evidence while others are still pricing it on averages.
See What Your Models Are Missing
Talk to our team about how public disclosure analysis can bring the £2m–£100m mid-market into focus across your commercial portfolio.
