Benchmarking Private Market Investor Climate Disclosures

Foreword

Phillip Marks - Unwritten, CEO

Welcome to the second edition of the Private Markets Climate Disclosures Benchmark.

I'm delighted to share this year's Unwritten benchmark of climate reporting in private markets. In terms of scale and analytical depth, this is our most comprehensive benchmark yet: we have expanded our review to 70 reports to build a robust evidence base. From the conversations that I have been having with Unwritten customers in the UK, Europe, North America and APAC regions, I know that the outcomes of our new trend analyses will provide an informative signal on the direction of travel for reporting. Check out my three highlights from this year's report below:

• North American GPs are formalising top-level endorsement: following a five-fold increase, 47% of reports now feature a foreword or commentary from an ExCo member, signalling clear senior sponsorship of the firm's climate progress.
• Our analysis reveals a stark “implementation gap”: while nearly two-thirds of firms have embedded climate risk assessment into pre-investment due diligence, only 13% maintain this rigour throughout the investment lifecycle.
• UK managers are driving the standard for reporting cadence: 64% of UK firms published fresh, portfolio-specific results for 2025, reflecting a significantly higher commitment to annual analysis updates than any other region.

I hope that our benchmark helps you to navigate the key decisions on the scope and depth of your climate and nature reporting in 2026.

Reporting Approach & Governance Insights

Trend 1 - Public, senior sponsorship of climate reporting has ascended for North American GPs

While UK and European firms this year maintained a steady, high level of sponsorship of their climate reporting using an introductory statement (or similar) from the fund's ExCo, North American firms saw a five-fold increase in disclosures featuring this type of commentary, surging from 8% to 47% in just one year. This change is likely explained by the need for North American GPs to signal intent around robust climate risk management, in reaction to the increasing pressure brought by some European and Asian LPs to integrate such practices into investment processes.

Trend 2 - UK FCA rules on TCFD reporting have likely driven a flight from freer-form climate reporting to a technical chapter within a broader sustainability report

The UK is the only region that sees a decline in the use of standalone reporting in 2025, likely driven by a reaction to this regulatory trend. In contrast to the UK market, North American GPs have more than doubled their use of standalone reports for climate disclosures. This divergence suggests North American managers are decoupling 'climate' from the general 'ESG' narrative, treating it as a distinct technical discipline that requires a distinct report.

Trend 3 - Year-on-year analysis reveals that half of managers are leveraging up-to-date assessment data to draw conclusions

Against a backdrop of regulatory rollback and geopolitical turbulence on climate, 47% of managers disclosed new, portfolio-specific climate risk assessment results this year. This is an impressive milestone, given the breadth of managers sampled for this benchmark and the complex process of coordinating an updated, annual climate risk assessment. However, we find that the remaining half of the market relies on stale, ambiguous or incomplete disclosures: 6% reused historical results; 23% limited their disclosure to high-level descriptive text; and 24% did not publish results at all.

Trend 4 - Nature reporting remains in its infancy, characterised by a sharp drop-off between broad risk assessment and risk quantification

While over a third (36%) of managers now mention broadly assessing biodiversity risks in their investment process, only 14% disclose fund-wide results of nature-related risk assessment in their public disclosure. Of those 14%, the majority disclosed high-level qualitative descriptors or simple graphics explaining nature & biodiversity impacts or dependencies. A handful of managers from that subset disclosed detailed results or a complete, TNFD-aligned report. Managers are piecing together their nature risk assessment practices but we expect it could be some years before widespread disclosure of fund-wide assessment results can be found in reporting.

Strategy and Risk Management

Trend 5 - Investors are formalising climate risk assessments during pre-investment due diligence, yet an “implementation gap” prevents consistent integration into ongoing stewardship

We have analysed the descriptions used by every GP in our sample with respect to their integration of climate risk assessment into their investment process. We find that GPs typically sit in one of four approaches. While nearly two-thirds of firms have embedded their climate risk assessment into initial screening, only 13% maintain this rigour throughout the entire investment lifecycle from acquisition to exit. This disconnect suggests that many GPs still view climate risk as a pre-acquisition diligence item: a factor assessed to approve a deal but not monitored as a dynamic exercise throughout the hold period. In contrast, industry leaders are “closing the loop” by embedding climate metrics into post-acquisition value creation planning. Underpinning this approach is the belief that those GPs can foster higher multiples on exit by ensuring assets remain resilient to shifting regulations and disruption from physical climate risks.

Trend 6 - UK managers are significantly more likely to refresh analysis on an annual basis, ahead of reporting

When we isolate our sample for just the managers that published new, portfolio-specific results for 2025, UK firms are most likely to produce up-to-date annual reports compared to other regions. Beyond the UK, the share is balanced: North American managers make up 18% of this dynamic reporting cohort, holding an equal share to their European peers (18%). This somewhat challenges the standard narrative of European maturity on climate reporting; it suggests that in the specific discipline of producing refreshed, annual disclosures, a committed cohort of North American firms is matching the operational rigour of their European counterparts.

Trend 7 - UK and APAC managers have established a clear lead in disclosing specific climate risks, outpacing European and North American peers

UK and APAC situated managers were most likely to disclose precise transition and physical risks in their 2025 reporting. Although our APAC sample is small, compared to the total number of private managers in the region, this finding serves as a powerful signal that major APAC managers are leapfrogging the 'generic disclosure' phase directly into detailed, asset-level reporting. The low rate of specific risks being reported by North American funds likely reflects a strategic decision to avoid disclosing this data in public reports to avoid anti-ESG scrutiny.

Figure: Proportion of disclosures naming specific transition risks - UK: 61%; Europe: 38%; North America: 32%; APAC: 57%. Proportion naming specific physical risks: 21% (aggregate figure shown in source).

Trend 8 - Scenario analysis has firmly established itself as the core analytical framework for understanding climate risks

Our results show that climate scenario analysis is now a well-established analytical framework for private managers seeking to understand and communicate climate risks. Adoption rates vary slightly by region. The UK leads the field, with over 80% of managers assessing both transition (86%) and physical (82%) risks. Notably, APAC managers have matched this adoption rate, signalling strong alignment with global best practices. North American and European adoption sits lower at 74% and 69% respectively, suggesting that roughly a quarter of managers in these markets are choosing to deprioritise this type of modelling.

Figure: Proportion of managers conducting scenario analysis for transition risks - UK: 86%; Europe: 69%; North America: 74%; APAC: 86%. For physical risks, the UK figure shown is 82%.

Metrics & Targets

Trend 9 - Almost all managers are continuing to disclose carbon emissions across Scopes 1, 2, and 3

Trend 10 - North American disclosure of portfolio coverage rises as European reporting recalibrates under new regulatory standards

Over one in five North American managers in our sample have doubled their SBTi portfolio coverage target reporting, while UK and European figures have declined to 61% and 69%, respectively. This contraction could be tied to the introduction of the SBTi's FINZ standard in July 2025 and the subsequent transition period that has been established (through until December 2026). Managers may have elected to temporarily pause their SBTi portfolio coverage reporting in the public domain whilst they build capacity to report under the new regime. Our sample increases from 2024 to 2025 but directionally our trend conclusion holds as we observe funds that have reports in both vintages removing their SBTi target coverage analysis, and we see few new funds in our 2025 vintage reporting their target coverage data.

Trend 11 - Adoption of net-zero alignment frameworks is surging

UK, European, and North American adoption of net-zero alignment frameworks has seen dynamic growth. High disclosure levels signal a milestone for the reporting metrics leveraged by these frameworks, principally driven by LP demand. Investors no longer accept “black box” methodologies and are pushing for comparable, transparent framework usage. Consequently, the Private Markets Decarbonisation Roadmap (PMDR) has emerged as the dominant framework, providing the essential “common language” managers need to prove the credibility of their decarbonisation plans to institutional capital.

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