As of June 3, 2026, the Bank of England’s Prudential Regulation Authority (PRA) began formal supervisory enforcement of Supervisory Statement SS5/25. The six-month grace period is over. Climate-related risk is now regulated as a first-order Prudential Financial risk for UK insurers, placed in the same category as credit, market, and operational risk, with the same expectation of board-level accountability and evidenced management.
For claims operations, two areas of the PRA’s assessment framework carry immediate implications: data gaps and operational resilience. Both point to the same part of the insurance value chain that has historically been the hardest to measure and the easiest to overlook: the claims supply chain.
The PRA’s expectation is clear. Insurers must take a forward-looking, strategic and ambitious approach to embedding climate risk into day-to-day operations. This is not a disclosure exercise or a reporting checkbox. It is a risk management obligation with teeth.
The PRA will assess insurers across eight areas: governance and board understanding, risk frameworks and appetite, underwriting and reserving, capital and stress scenarios, Solvency Capital Requirement, data and data gaps, operational resilience, and climate scenario analysis. Insurers who have identified gaps are not automatically penalised, but those gaps must come with a remediation timetable that is “both credible and ambitious.”
What does that mean in practice? Insurers need to show the work. They need to demonstrate how they are identifying climate-related risks, how they are managing them, and where the data does not yet exist, how they plan to get it.
When a storm, flood, or fire damages a property, the insurer funds the repair. That means contractors, materials, transport, waste disposal and project management, all of which carry a carbon footprint, and all of which are directly exposed to physical climate risk.
The PRA specifically assesses how insurers plan to remedy gaps in climate-related data, including contingency solutions where actual data is not available. For the vast majority of insurers, the claims supply chain is exactly that gap. Emissions data at the claim level, by contractor, by material, by peril, is either non-existent or built on broad benchmarks that do not reflect what is actually happening on the ground.
This matters for two reasons. First, benchmarked data cannot satisfy the PRA’s expectation of genuine risk identification. Second, without actual supply chain data, an insurer’s climate scenario analysis is built on assumptions rather than evidence, which is precisely what regulators will be testing during supervisory reviews.
That is the gap EcoClaim TRAX™ was designed to fill.
EcoClaim TRAX™ is purpose-built for the insurance industry. It tracks actual greenhouse gas emissions at the claim level, across every stakeholder in the supply chain: adjusters, MGAs, contractors, and recyclers. Rather than applying industry benchmarks after the fact, TRAX captures real data from real claims, giving insurers a PCAF and TCFD-compliant picture of their Scope 3 footprint that can be reported, audited, and defended.
Crucially, TRAX also quantifies carbon avoidance: the emissions that were not generated because of better material choices, waste diversion, or repair over replacement decisions. This is not just a compliance tool. It is a performance tool. Insurers using TRAX have reduced claims costs by up to 30% through improved supply chain efficiency and reduced waste.
For SS5/25 purposes, TRAX provides exactly what the PRA is asking for: actual data, at the claim level, with documented methodology and a clear pathway from benchmarks to real measurement.
Learn more: ecoclaim.ca/trax
Operational resilience under SS5/25 is about an insurer’s ability to continue providing services under climate stress, including through outsourced and third-party arrangements. For claims operations, this raises a question that goes beyond carbon accounting: is the supply chain making the problem better or worse over time?
This is where Rebuild Better™ comes in. At the point of a claim, insurers have a decision-making opportunity that is often underused. The materials specified, the quality of repair, the resilience of the rebuild: these choices determine whether the same property generates another claim in the next hail storm, flood, or wind event.
Rebuild Better™ gives insurers and their supply chain partners the data to make those decisions at the point of loss. Replacing a roof with more durable, impact-resistant shingles costs more today, but eliminates or significantly reduces the next claim. That is not just better for the environment. It is better for the loss ratio. Resilience built into the supply chain, claim by claim, is the most direct form of climate risk management available to an insurer.
Learn more: ecoclaim.ca/rbb-brochure
For a full breakdown of SS5/25 and what the PRA’s enforcement approach means for insurers, we recommend reading the analysis published by WTW’s Director of Climate and Sustainability, Michelle Radcliffe.
“The SS5/25 Deadline: Embedding Climate Risk in Day-to-Day Insurance Operations” Michelle Radcliffe, WTW, June 15, 2026
SS5/25 is not a future obligation. It is a current one. The PRA has named the problem areas: data gaps, scenario analysis, resilience, governance, and it is now assessing how insurers are responding.
For claims operations, the supply chain is where the most significant data gap exists, and where the most direct resilience opportunity lies. Insurers who have not yet mapped their claims supply chain emissions are operating with a blind spot the regulator can now act on.
The question is not whether this matters. It is how quickly the data infrastructure can be put in place.
EcoClaim helps insurers measure, manage, and reduce Scope 3 emissions across the claims supply chain. To learn more about EcoClaim TRAX™ or Rebuild Better™, visit ecoclaim.ca.
