A forced-labour screen that was accurate at onboarding can be worthless six months
later if the supplier quietly changes subcontractors. A deforestation attestation can
become indefensible if the underlying coordinates were never refreshed.
Supplier due diligence has spent a decade built around a single moment: onboarding.
The questionnaire goes out, the supplier responds, the file gets a tick, and everyone
moves on until the next annual review.
That model is no longer defensible for insurers, reinsurers and underwriters who need
to price non-financial risk with confidence — because the risk itself doesn’t stay still
between reviews.
Why the Point-in-Time Questionnaire Fails
A questionnaire captures one moment. Ownership structures shift, sourcing origins
change, certifications lapse — none of it shows up until the next cycle, if it’s even asked
about again.
Questionnaires also depend on the supplier’s willingness and capacity to respond well.
Many are slow, incomplete, or answered by whoever has time that week, not whoever
holds the information.
Stale supplier data is increasingly treated as one of the more underestimated risk
exposures in supply chain oversight, precisely because it looks current on file long after
it has stopped being true.
What Continuous Data Collection Replaces It With
Rather than waiting for a supplier to self-report, continuous public disclosure analysis
builds a live picture from what companies already put into the public domain:
- Website disclosures and stated policies
- Published sustainability and ESG reporting
- Certifications and accreditations
- Regulatory filings and policy documentation
This data is monitored on an ongoing basis rather than refreshed once a year, so a
change in a supplier’s disclosed practices surfaces as it happens — not eleven months
after the fact. It also gives underwriting and portfolio teams a documented evidence
trail behind every score, so exposure isn’t just “the supplier says so.”
Why 2027 Is the Turning Point
Regulatory timelines are pushing the same direction. The EU Deforestation Regulation’s
application window now runs through 2027 for smaller operators, extending traceability
obligations further down supply chains than most static questionnaire programmes
were built to handle.
For insurers and reinsurers, this sits alongside existing obligations under ORSA,
Solvency II and frameworks like SFDR and TNFD, where portfolio-level climate and
sustainability risk needs to be demonstrable, not just declared.
What This Means for Insurers, Reinsurers and Underwriters
A supplier or counterparty’s risk profile is not a fixed fact established once at
onboarding — it’s a moving target. Underwriting and portfolio risk teams that rely solely
on periodic questionnaires are pricing risk on data that is often already out of date.
Public Disclosure Analysis gives underwriting, portfolio risk and supplier management
teams a consistent, continuously updated view across sectors and industries — built
for defensibility under SFDR, TNFD, TCFD and ORSA, not just for filing away.
Explore Public Disclosure Analysis
If your onboarding process still ends the moment the questionnaire is filed, talk to TDH
about how Public Disclosure Analysis keeps that picture current across your portfolio.
