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Suncorp Group Limited

ASX: SUNIndustry: InsuranceAuditor: KPMGFY2026Group: Group 1
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GovernanceGovernance

AASB S2 paragraphs 5–7, Aus7.1

Governance body oversight and management's role

Reported

Board (p. 43). The SGL Board is responsible for oversight of climate-related risks and opportunities (CRROs) across Australia and New Zealand, assisted by Board Committees (responsibilities set out in their Charters). It is informed of CRROs and of progress against climate-related metrics and targets at least annually, and approves the Annual Report, the Climate Transition Plan with its metrics and targets, the business plan and budget, the natural hazard allowance and the annual reinsurance program, and oversees funding to manage CRROs. The Board Risk Committee approves climate-related risk appetite and reviews and approves scenario analysis and outcomes; the Board Audit Committee oversees financial and sustainability reporting. Directors self-assess annually against a skills matrix that embeds capabilities to manage physical and transition risks.

Management (p. 44). The CEO is accountable for overseeing and managing CRROs, with responsibilities delegated to Executive Leadership Team members, including the CFO (climate-related targets, scenario analysis, reinsurance) and the CRO (second line oversight of CRROs). Climate-related risks are incorporated into risk management processes and may be escalated to the Board; consideration of trade-offs is inherent.

Remuneration (p. 44). CRROs are reflected in executive remuneration through the financial and risk measures in the Suncorp Scorecard, with no standalone climate measures or separate weighting.

StrategyStrategy

AASB S2 paragraphs 10–11

Climate-related risks and opportunities

Reported

CRROs identified (pp. 25–32). Suncorp categorizes CRROs as physical risks, transition risks and climate-related opportunities. Six are identified, each page marked with its time horizons (S, M, L):

CRROTypeHorizonsPage
Risk 1 Increasing weather-related claims costsPhysical riskS, M, L26
Risk 2 Claims capability and capacityPhysical and transition riskS, M, L28
Risk 3 Reinsurance pricing and capacityPhysical riskS, M, L29
Risk 4 Home insurance market interventionPhysical and transition riskM, L30
Opportunity 1 Disaster management response and recoveryPhysical opportunityS, M31
Opportunity 2 Transition-related products and market opportunitiesTransition opportunitiesS, M, L32

Time horizons (p. 25). Short: less than 3 years, aligned with the three-year business planning cycle. Medium: 3 to 20 years, where risk management processes identify and respond to emerging risks and strategic disruption. Long: more than 20 years, capturing impacts beyond the short and medium terms.

Also considered (p. 30). Fossil fuel related stranded asset risk is determined to be low for the listed equities and corporate bonds investment sub-portfolio, because of the fossil fuel exclusions in the Sensitive Sector Standard.

AASB S2 paragraph 13

Business model and value chain

Reported

Physical risk to claims (p. 26). Changes in the frequency and severity of weather events may increase natural hazard claims costs and affect insurance risk and reinsurance outcomes, flowing through to pricing and customer affordability. Peril exposure is primarily severe storms, bushfires, tropical cyclones and flooding along the Eastern Seaboard of Australia, predominately affecting property-related insurance products.

Concentration (p. 28). Insurance exposure is heavily concentrated in property classes: home with $4.3 billion of Gross Written Premium (GWP), 28.1% of overall GWP, and motor with $6.6 billion, 42.5% (Compulsory Third Party excluded). In FY26 there were 18 declared natural hazard events and more than 120,000 natural hazard claims, which can create surge demand across the claims network. Uptake of solar panels and electric vehicles adds capacity pressure because repairs need training, specialized equipment and parts.

Other effects (pp. 29–32). Severe weather may affect the pricing and availability of reinsurance and capital (p. 29). Higher home insurance premiums and affordability concerns may lead to further government intervention, affecting the operating environment, cost base, underwriting, pricing models and capital requirements (p. 30). Disaster management capability supports management of claims costs and post-event demand (p. 31). The transition is expected to raise demand for insurance solutions for transition-related assets (p. 32).

AASB S2 paragraph 14

Strategy and decision-making

Reported

Responses by CRRO (pp. 27–32). Reinsurance: a five-year aggregate cover and optimization of structure, attachment points and limits. Underwriting: address-level pricing, aggregate exposure guardrails and enhanced climate forecasting. Claims: Trans-Tasman surge capacity. Disaster management: a staged $25 million jobs and investment package over FY23–FY28 (p. 31). Opportunities: motor insurance for drivers of electric and hybrid vehicles, Digital Insurer, and an annual commitment of 5% of AAI Limited shareholder funds to social impact and lower-carbon impact investments (p. 32).

Climate Transition Plan (pp. 37–38). The Plan, released in the FY25 Climate-related Disclosure Report, is summarized: net-zero Scope 1 and 2 by end FY30 from an FY20 baseline; RE100 commitment of 100% renewable electricity in 2025; and a financed emissions intensity target for listed equities and corporate bonds. Implementation covers major procurement suppliers (50 suppliers; 74% publicly disclose Scope 1 and 2), claims panel builders and motor mobility suppliers, engagement with 100% of external investment managers each year, and fossil fuel exclusions under the Sensitive Sector Standard, met in FY26.

Assumptions and resourcing (pp. 32, 39). The net-zero target assumes competitive renewable electricity products and ongoing supply of hybrid and electric vehicles through FY30. Capital is deployed through business-as-usual activities and existing budgets, not allocated separately to CRROs.

AASB S2 paragraphs 15–21

Financial position, financial performance and cash flows

Partial
Partial disclosure: Effects are quantified for weather-related claims costs (FY26 amounts, FY27 allowance and scenario ranges, pp. 26-27) and reinsurance (FY26 premium and FY27 structure, p. 29), with only a motor portfolio amount and a lower-carbon investment amount for transition opportunities (p. 32). The rest are stated as not separately identifiable (claims capability, p. 28; other lower-emissions technologies, p. 32), too uncertain to quantify (home insurance market intervention, p. 30) or not reliably separable (disaster management benefits, p. 31), and quantitative combined effects are said not to be useful (p. 32). The report cites no AASB S2 paragraph for not quantifying. It does not say whether any CRRO carries a significant risk of a material adjustment to carrying amounts within the next reporting period (16(b)) and gives no planned sources of funding (16(c)(ii)); capital is said to be deployed through business-as-usual activities and existing budgets (p. 32).

Current effects (pp. 26, 29, 32). FY26 natural hazard claims costs were $2,024 million (FY25: $1,355 million), 19.8% of total claims expenses and $254 million above the $1,770 million natural hazard allowance, within the insurance services expense line item. FY26 reinsurance premium was $40.2 million; its climate-related share cannot be separately identified. Transition growth is reflected in motor portfolios ($6.6 billion, 42.5% of Group GWP); $1,188 million was invested in lower-carbon impact investments.

Anticipated effects (pp. 26–29). The FY27 natural hazard allowance is $1,850 million. Relative to the FY26 net natural hazard allowance for weather-related perils, climate change is expected to raise net natural hazard costs by 3% (low warming) to 7% (high warming) around 2040 and by 3% to 11% around 2050, excluding inflation and unit growth. A five-year aggregate reinsurance cover ($800 million per annum, up to $2.4 billion in total) is expected to cap natural hazard costs at $1.85 billion in FY27 in approximately 90% of scenarios.

Not quantified. Claims capability and capacity: not separately identifiable (p. 28). Home insurance market intervention: high measurement uncertainty (p. 30). Disaster management: no material effect in FY26 or readjustment expected in FY27 (p. 31). Transition opportunities: reliable quantification not supported by available data (p. 32). Combined effects: quantitative information would not be useful at this time (p. 32).

AASB S2 paragraph 22

Climate resilience and scenario analysis

Reported

Scenario analyses (pp. 33–35). Three analyses; the investment portfolio was not in scope in FY26.

AnalysisScenariosHorizonsCarried out
Weather-related claims (physical)IPCC RCP2.6 low, RCP4.5 medium, RCP7.0 (New Zealand) or RCP8.5 (Australia) high warming2030, 2040, 2050FY25
Household insurance affordabilityNetwork for Greening the Financial System (NGFS)-aligned Current Policies and Delayed Transition2030, 2040, 2050FY25
Australian insurance value chain (transition, qualitative)Transition scenario #1 (2.1°C–3.5°C by 2100); #2 (1.5°C by 2100, disorderly)to 2030; to 2040–2050FY24, reviewed FY26

Transition scenario #2 is described as consistent with the latest international agreement on climate change (p. 35).

Assessment (p. 36). Suncorp's strategy and business model are considered resilient to current and anticipated physical and transition risks over the short, medium and long term. Projected natural hazard cost increases are manageable through risk-based pricing, capital management and reinsurance; over the longer term, resilience is increasingly influenced by external factors such as affordability pressures and government intervention. Adaptive capacity: financial flexibility, operational capability and underwriting discipline. The assessment assumes existing risk management frameworks and controls operate as intended.

Risk ManagementRisk Management

AASB S2 paragraphs 24–26, Aus26.1

Processes for identifying, assessing and managing climate-related risks

Reported

Integration (p. 42). The Risk Appetite Statement and Enterprise Risk Management Framework recognize physical and transition risks, treated as standalone risks and as causes of other risks, managed under documented practices and prioritized by risk rating. Climate-related risks are managed through risk selection, natural peril pricing, the natural hazard allowance, reinsurance, capital and advocacy. Scenario analysis is a risk management tool; outcomes inform strategic and risk management decisions but do not determine annual risk ratings.

Risks (p. 42). Material natural perils are reviewed by the insurance pricing team using modeling that combines historical claims experience with climate, event and building construction information, and monitored using climate indices tracking weather extremes.

Opportunities (p. 42). Identified, assessed, monitored and prioritized through the annual business strategy development cycle, based on regulatory and strategic importance.

CRRO identification (p. 42). Four steps: identification and description (risk documentation, prior disclosures, scenario analysis, external frameworks, strategy documents, peer disclosures); elaboration and refinement (short, medium and long term, on a residual risk basis, with quantitative indicators where feasible); assessment of relevance and material information (Risk, Obligation and Control Self-Assessment processes); and final determination by governance and decision-making committees.

Metrics & TargetsMetrics and Targets

AASB S2 paragraphs 29–31

Climate-related metrics

Partial
Partial disclosure: Scope 3 is deferred under the first-year transitional relief the report says it elected (p. 41); no paragraph number is printed and the relief corresponds to C4(b). Only select categories are given voluntarily: upstream Categories 3, 5, 6, 7 and 8, and Category 15 financed emissions for a listed equities and corporate bonds sub-portfolio. No amount or percentage of assets or business activities vulnerable to transition or physical risks or aligned with opportunities is presented as a metric (29(b) to (d)); GWP concentrations and an amount invested in lower-carbon impact investments appear in the Strategy section (pp. 28, 32). No percentage of executive remuneration linked to climate considerations is given (29(g)(ii)); the report says there are no standalone climate measures. The Scope 1 and 2 boundary is operational control and excludes the subsidiary AA Insurance New Zealand and joint venture entities, with no separate figures given for them (29(a)(iv); p. 45).

Emissions (p. 41). Operational control approach, in accordance with the Greenhouse Gas Protocol; measurement approach on pp. 45–47. FY25 comparatives are voluntary; FY25 Scope 2 figures were restated (footnote 2).

tCO2-eFY26FY25
Scope 11,5661,286
Scope 2 – location-based4,0196,228
Scope 2 – market-based0740
Scope 3 upstream, Categories 3, 5, 6, 7, 8 (voluntary)15,01217,695
Scope 3 Category 15 financed emissions (voluntary)326,678322,610

Suncorp elected the transitional relief to defer mandatory Scope 3 emissions to the second year of reporting, and says the Australian Accounting Standards Board has determined that Scope 3 insurance-associated emissions from underwriting are not required (p. 41). The subsidiary AA Insurance New Zealand and joint venture entities are outside the Scope 1 and 2 boundary (p. 45).

Other metrics. No carbon price is used to inform emission reduction decisions (p. 39). Executive remuneration has no standalone climate measures and no separate weighting (p. 44). $1,188 million was invested in lower-carbon impact investments in FY26 (p. 32). Electricity purchased and self-generated was 8,213 MWh (FY25: 11,612), reported as additional information not required under AASB S2 (p. 41).

AASB S2 paragraphs 33–36, Aus37.1

Climate-related targets

Reported
TargetMetricBaseByFY26FY25
Operational Scope 1 and 2 net-zeroAbsolute Scope 1 and 2 (market-based), tCO2-eFY20: 13,065End FY301,566 (88% reduced)1,873 (86%)
RE100% MWh renewable electricity purchased or self-generated–2025100%89%
Financed emissions, listed equities and corporate bondsInvestees' Scope 1 and 2 emissions intensity, at least 60% lowerFY20End FY3076.4% reduced; 25.0 tCO2-e/$m76.6%; 24.8

Scope 1 and 2 (p. 39). At least 90% absolute reduction from FY20, with residual emissions abated through carbon credits. No carbon credits are currently used; if used, limited to no more than 10% of FY20 baseline emissions. The target is informed by the Science Based Targets initiative, is not derived using a sectoral decarbonization approach and has not been independently validated. The FY20 baseline was restated from 13,078 tCO2-e. RE100 performance is internally verified and not endorsed by RE100.

Financed emissions (p. 40). Set with reference to the Net-Zero Asset Owner Alliance (NZAOA) protocol, which recommends targets consistent with a 1.5°C global temperature limit (40-60% reduction by 2030); the target is at the upper end of that range. Methodology and target have not been validated by a third party. No carbon offsets are intended.