Submissions
11 April 2023: Consultation on National Adaptation Plan Issues Paper
The Institute encourages a bold and ambitious vision for the Plan. We encourage greater consideration of the uncertainty of the impact of climate change and the resources available to assess, manage and adapt to it than is indicated in the consultation paper. We suggest an additional objective of the NAP should include driving the substantial uplift in public sector investment required, as well as public and private sector partnerships. We emphasise the importance of strengthening and future-proofing building codes and land use planning rules.
29 February 2024: Submission - Exposure Draft - Australian Sustainability Reporting Standards
The Institute strongly supports the work of the AASB in drafting the ASRS Standards, and supports the initially narrowed focus to climate risk and intended expansion to broader sustainability at a later time and phased implementation across reporting entities. There are, however, a few areas of concern, including: international consistency with IFRS S1 and IFRS S2; treatment of superannuation entities; supporting comparability of entities’ climate resilience; and support for implementation and education.
1 December 2023: Submission to Treasury Consultation - Sustainable Finance Strategy
The Institute supports the key objectives of the Sustainable Finance Strategy, which will be a critical foundation to supporting the Government’s emissions reduction target and an orderly and positive economic transition. The submission responds to various issues including disclosures, awareness and education, provision of simplified and free resources, greater collaboration across parts of government and regulators to further improve modelling and understanding of the transition, and concern that the YFYS performance test constrains activities relating to ESG, sustainability and carbon transition.
17 December 2021: Response to Treasury – Exposure Draft Legislation –Cyclones and Related Flood Damage Reinsurance Pool
This response to the ‘Exposure Draft Legislation – cyclones and related flood damage reinsurance pool’ draws on the Institute’s 18 June 2021 submission to the initial consultation. However, additional comments are provided in this submission, including: 1) technical clarification of the Event Definition – the Institute suggests the definition should look to past events to understand how the pool definitions will apply in practice and resolve issues related to claims which may fall outside the draft pool definitions; 2) Transparency and disclosure of data and the pricing framework – the Institute generally supports Treasury’s pricing schedule for the cyclone and related flood damage reinsurance pool to improve transparency and confidence; and 3) other risk control measures – we refer to the Institute’s Property Insurance Affordability Paper from November 2020 for additional policy measures to address risk reduction.
26 November 2021: Actuaries Institute Letter to Geoscience Australia on Improving the Resilience of Households and Communities to Natural Perils
The Actuaries Institute understands Geoscience Australia is seeking to establish the factors that affect vulnerability of communities to severe wind events. One of the lenses into understanding that vulnerability is insurance uptake and affordability among the communities. At the request of Geoscience Australia, the Institute has analysed the following six local government areas (LGAs): Noosa Shire, Sunshine Coast, Moreton Bay, Redland City, Brisbane City and the City of Gold Coast.
16 September 2020: Actuaries Institute Submission to Counsel Assisting the Royal Commission into National Natural Disaster Arrangements
The Actuaries Institute commends Counsel Assisting for its considered and extensive Interim Observations and Draft Propositions on this issue of growing national importance. The Institute supports many of the draft propositions and has separately submitted a completed Draft Propositions Response Table in the requested electronic format.
21 May 2020: Notice to Give Information (Witness Statement) to Royal Commission into National Natural Disaster Arrangements
Witness Statement by Sharanjit Paddam, Convenor of the Actuaries Institute Climate Change Working Group, to the Royal Commission.
16 April 2020: Actuaries Institute Submission to Royal Commission into National Natural Disaster Arrangements
The Institute notes that immediate emergency response is critical in the preservation of life and an important part of disaster arrangements, but we have confined our comments in this submission to issues regarding mitigation and adaptation, insurance and long-term financial recovery for communities. This submission synthesises the findings from the Institute’s body of work under four main areas: natural disasters in Australia, the changing climate, affordability of insurance and health impacts.
10 October 2019: Northern Australia Insurance Inquiry - Second Update Report
The Actuaries Institute ("the Institute") welcomes the opportunity to comment on this report.