As a leading global property and casualty insurer, Liberty Mutual Insurance has long understood the impact of the transition to a low-carbon economy and the role insurance plays. We actively support a responsible transition in various ways, including making operational emissions reductions, conducting new climate risk research and supporting our customers in their journeys. In addition, we seek to participate in collaborative industry dialogue with the goal of developing meaningful solutions to support the energy transition. With this in mind, we joined the Partnership for Carbon Accounting Financials (PCAF) Insurance-Associated Emissions Working Group in their effort to create a framework for measuring this Scope 3 data – offering the perspective of a US-based, global carrier in the dialogue. 

Today PCAF shared the first version of this standard, which we believe demonstrates both progress and continued areas for improvement. In particular, we see opportunity to continue evolving the standard so that it further considers the nuances of how insurance is regulated and operates in different markets. From a US lens, as written today, in addition to potential legal and regulatory risks with the standard's implementation, the approach also has the potential to create unintended consequences for the US economy and our most vulnerable communities.

We acknowledge the complexity of the energy transition and reaffirm our commitment to continued industry collaboration in the pursuit of applicable, meaningful global solutions. 

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