ESG reporting in South Africa moved from optional to mandatory in 2025. Most insurers responded by handing the work to the sustainability function. We think that is the wrong owner. Insurer ESG reporting is climate-risk reporting in a different filing — and the actuarial team is the function with the discipline, the data, and the audit trail to do it well.
What changed in 2025
The change that matters is not “ESG is now important”. ESG was important for years. The change is that disclosure is now an enforced requirement, audited under the same scrutiny as IFRS numbers, with named reporting frameworks the regulator and JSE expect a listed insurer to follow.
Three frameworks dominate in the South African insurance context. The Task Force on Climate-related Financial Disclosures (TCFD) drives climate-specific reporting — risks, scenarios, governance, metrics. The Global Reporting Initiative (GRI) covers the broader Environmental / Social / Governance landscape. The Sustainability Accounting Standards Board (SASB), now under the IFRS Foundation, provides industry-specific metrics that connect ESG disclosure to financial materiality.
For insurers, our recommendation is unambiguous: lead with TCFD, supplement with GRI for the social and governance pillars, and use SASB for the industry-specific metrics. TCFD’s structure — governance, strategy, risk management, metrics and targets — maps directly onto the actuarial control environment. The other two are complements, not alternatives.
Why actuarial should own this
The sustainability function in most insurers is set up to write reports. The actuarial function is set up to defend numbers. ESG disclosure is now the latter problem. Numbers in an audited ESG report need:
- A defined methodology, recorded and version-controlled.
- Source data with lineage, traceable from disclosure back to the policy file or asset record.
- A reasoned position on uncertainty, especially for forward-looking climate scenarios.
- Reproducibility — last year’s numbers need to be regeneratable from versioned inputs when the auditor asks.
That is the actuarial control environment, applied to ESG metrics. The sustainability function does not, in most insurers, have the apparatus to do this. The actuarial team does. Outsourcing it to a non-actuarial function is creating exactly the kind of unaudited overlay layer we have been arguing against.
Environmental metrics
The environmental disclosures with the most direct insurance-actuarial relevance are GHG emissions, energy use and water management. Each has an established calculation methodology and a recognised source.
| Metric | What gets reported | Method / standard |
|---|---|---|
| GHG Emissions (Scope 1–3) | CO₂e from direct operations (1), purchased energy (2), and value chain (3) — including financed emissions for insurers’ investment portfolios | GHG Protocol; SA Carbon Tax Act 2019 |
| Energy use | Total energy by source; renewable share; intensity per unit of business activity | GRI 302 |
| Water management | Withdrawal, reuse, scarcity exposure of operations | GRI 303; SASB sector standards |
For insurers, the disclosure that the regulator and the audit will probe hardest is Scope 3 — financed emissions. That is the climate footprint of the assets the insurer holds and the reinsurance counterparties it transacts with. Producing this number defensibly is a data engineering and actuarial exercise, not a sustainability survey.
Social metrics
The social pillar in South Africa is shaped by domestic legislation as much as by global frameworks. Three metrics carry most of the disclosure weight.
| Metric | What gets reported | Method / standard |
|---|---|---|
| Diversity, Equity, Inclusion | Workforce composition by race, gender, disability; pay-gap disclosure | Employment Equity Act 1998; GRI 405 |
| Health & Safety | LTIFR, incidents, OHS Act compliance | OHS Act 1993; GRI 403 |
| B-BBEE Scorecard | Ownership, skills development, supplier and enterprise development spend, level achieved | B-BBEE Act 2003 |
The B-BBEE scorecard, in particular, is well-instrumented in most listed insurers. It is also the disclosure most often quoted incorrectly when the underlying data is not under actuarial-grade control — figures published in the integrated report do not match figures filed with the verification agency, and nobody can explain the difference.
Governance metrics
| Metric | What gets reported | Method / standard |
|---|---|---|
| Board composition | Independence, diversity, executive vs non-executive ratio | King IV; GRI 405 |
| Ethical conduct & compliance | Anti-bribery policy, whistleblower protection, ethics violations reported | Protected Disclosures Act 2000; King IV |
| Tax transparency | Tax paid by jurisdiction; effective tax rate; reconciliation to statutory rate | OECD Tax Transparency in Africa; King IV |
Companies already doing this well
A short list of South African issuers whose 2023–24 ESG disclosures are credibly structured, useful as comparators when scoping your own:
- Sasol — Scope 1, 2, 3 emissions, energy intensity, water withdrawal by source, carbon-tax compliance, plus disclosed investment in green hydrogen and carbon capture.
- Nedbank — board-diversity reporting, financed-emissions footprint of the loan book, green-bond allocation, ESG-aligned SME finance disclosure.
- MTN — digital-inclusion metrics, carbon-reduction targets, community-engagement reporting.
- Standard Bank — Equator Principles alignment, sustainable-finance flow tracking, UN SDG mapping.
- Discovery — health-outcome reporting, employee wellness, shared-value business-model disclosure.
How to start
If your insurer is treating ESG reporting as a sustainability-function compliance exercise, the first move is small and political: have the actuarial function take ownership of the numbers in the report, not the narrative around them. The narrative can stay where it is. The numbers — and the data and methodology behind them — should sit under actuarial control.
The second move is technical: instrument the underlying data. Scope 3 financed emissions are not a survey question; they are a data engineering pipeline that joins the asset register, sector classifications and emission factors. B-BBEE scorecard data is not a one-off pull; it is a versioned dataset with a methodology document. Tax-transparency disclosure is not a footnote; it is a reconciliation between statutory rate and effective rate that someone has to defend.
None of this is exotic actuarial work. It is the actuarial control environment, applied to a new set of metrics. The teams that get this right will spend much less time defending their ESG report at audit; the teams that do not will spend the next three years rediscovering, painfully, that mandatory ESG disclosure is just disclosure, with the same standards it has always had.
If you are scoping the actuarial side of an ESG reporting programme, our Finance Modernisation practice and our Data Engineering practice cover the pipeline, lineage and reproducibility that audited ESG disclosure now requires.