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AEMA GROUPE

AEMA

Groupe mutualiste de protection français.

Lobbying Activity

Meeting with Pierre Jouvet (Member of the European Parliament)

12 Nov 2025 · La santé globale dans toutes les politiques publiques

Response to Union prevention, preparedness, and response plan for health crises

28 Oct 2025

Aéma Groupe, a French mutualist insurance group and a major player in the social and solidarity economy, welcomes the opportunity to contribute to the development of the Union prevention, preparedness, and response plan for health crises. We believe that robust health systems, grounded in strong social principles, are essential catalysts for the European Union's long-term competitiveness and resilience. Our perspective, detailed in the enclosed document, centers on leveraging social investment, enhancing strategic coordination, and prioritizing comprehensive prevention at the European level.
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Response to The new Action Plan on the implementation of the European Pillar of Social Rights

10 Sept 2025

Aéma Groupe welcomes the opportunity to contribute to this call for evidence. First of all, as a French mutual insurance group and a major player in the social and solidarity economy, Aéma Groupe considers it essential to make the link between the Pillar of Social Rights and the European Union's compass of competitiveness. The two initiatives are deeply interdependent, with each principle of the Pillar being a catalyst for sustainable competitiveness. However, major progress is needed to turn the Pillar into a real strategic lever. Divergences among member States in the application of the principles hamper harmonization, which undermines the effectiveness of the current Action Plan. The lack of binding mechanisms and rigorous control is a major shortcoming. In addition, and as is often the case for social policies, the Pillar is isolated from economic policies and in particular from those of the European Semester. The EU should strengthen the integration of the Pillar into the European Semester, by introducing clearer and more binding indicators. Its principles should also be better aligned with the objectives of the EU's Competitiveness Compass, by clearly highlighting the economic benefits of social investment and linking social and economic policies. In addition, the document enclosed details our recommendations regarding the following principles: Principle 15: Old-age income and pensions Leveraging the Savings and Investment Union for sustainable retirement financing; Principle 12: Social protection - The key role of public-private partnerships; Principle 16: Health Care: A Comprehensive Plan of Action for Prevention; Principle 18: Long-term care An open data framework and investments for innovation; And Principle 20: Access to Essential Services: The need for a renewed commitment to the social economy, and the Right to Mobility.
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Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

4 Sept 2025

Aéma Groupe expresses support for the objectives of the Solvency II review, emphasising the need for a risk-sensitive prudential framework that enhances the competitiveness of the European insurance market. We highlight the importance of maintaining a level playing field, reducing operational burdens, and promoting long-term investment to enable insurers to fully contribute to economic financing. While welcoming some positive proposed changes, like the recognition of risk-mitigating effects of State guarantees or State reinsurance, we also raise concerns about some proposals that may undermine these goals and add complexity : Proposals on LTEI are insufficient to ensure the success of the measure: while the Commission supplemented LTEI no forced selling test approach with the coexistence of EIOPAs methodology, they remain excessively restrictive. The exclusion of financial bonds, limitations on funds and the severity of the stresses contribute to making the test disproportionately stringent. The approaches based on duration and liquidity buffer are based on overly restrictive criteria, notably with a duration threshold set at ten years for the life approach and the exclusion of assets held through liquid investment vehicles in the non-life approach. Also, the scope of funds eligible for simplified look through approach needs to be significantly widened. An appropriate definition of the VA is crucial to encourage long-term investments. The proposed definition of the CSSR should be improved as it does not correctly reflect the impact of spread widening on own funds. Risk margin: The reduction of the lambda factor to 96% is a positive step forward but still falls short of our expectations. The 50% floor should be dropped, as it unduly restricts the effectiveness of the lambda in supporting long-term guarantees. A lambda of 92.5% with no floor would allow the industry to remain competitive both in countries without a risk margin or with a lower calibration. The changes in the Interest Rate Risk SCR remains significantly overstated and might even become unbearable under certain market circumstances. It will substantially weigh on the benefits of the review, while creating a risk of unlevel playing field with other jurisdictions where such changes have not been foreseen or adopted. In that context, should these changes be adopted, Aéma Groupe is of the view that the interest rate SCR modification is a very negatively impactful component and that, given its significance, introducing a phasing in the changes is necessary. Beyond LTG elements, many proposals are seen as restrictive and operationally complex, particularly regarding reporting, the recognition of reinsurance in the standard formula or best estimates. In many cases, the proposed changes are neither necessary nor justified and would only increase operational and reporting burdens, disrupt the EU insurance market, impair its competitiveness and the SIU goals. In particular, the ability for supervisors to challenge availability of group EPIFP is not appropriate and could only lead to an unjustified deletion of own funds. Changing the treatment of EPIFP would undermine the consistency of the prudential framework, eliminate a key incentive to provide long-term guarantees by locking up capital in legal entities, preventing its use for economic growth or closing protection gaps. It will lead to additional burden for the industry, divergent supervisory practices, gold-plating or even inefficient group restructure.
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Response to European climate resilience and risk management law

4 Sept 2025

In a world increasingly marked by unprecedented crises and uncertainties, it is essential to protect European citizens from existing and worsening new and emerging vulnerabilities, in particular those stemming from climate change. Aéma Groupe proposes the following recommendations, detailed in the enclosed document, to strengthen Europe's climate resilience and risk management framework at the European level and reduce the protection gap: 1. Step up climate resilience efforts and mainstream prevention as a fundamental condition for insurability across the EU. 2. Create a European Climate Risk Research Institute to improve common understanding and preparedness for natural hazards. 3. Condition European financing mechanisms on compliance with climate resilience criteria, aligning public investments with adaptation objectives. 4. Put in place safeguards to prevent the demutualization of insurance, particularly in the context of the emergence of data access regulations. 5. Actively promote collective public-private investments focused on biodiversity and prioritise nature-based solutions for territorial adaptation. 6. Establish specific financial mechanisms for the mobilization of stable and long-term financing for ecological transitions and adaptation. 7. Promote a collective "risk culture" from primary school onwards and raising public awareness through accessible communication and training for professionals and local elected officials to mobilize the population in favour of climate adaptation. By fostering a regulatory framework that encourages collaborative efforts, prioritises long-term resilience and reinforces the principles of solidarity and mutualisation, the European Union can forge a new social contract that effectively responds to the protection needs of its citizens. We are committed to working with European decision-makers to implement these initiatives, ensuring that policies are visionary, pragmatic and truly beneficial for all European citizens. This holistic approach to consumer protection will foster a more sustainable, fairer and more resilient European future.
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Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market

29 Aug 2025

In a world increasingly marked by unprecedented crises, transformations and uncertainties, it is essential to protect European citizens from new and emerging vulnerabilities. This response sets out Aéma Groupe's views on some of the key transitions impacting consumers, proposing courses of action and highlighting the essential role of insurers in promoting a more protective, sustainable and resilient Europe. Our answer enclosed details some measures we propose to efficiently protect consumers in the face of: 1) Emerging and growing risks related to climate change; 2) the New Online Investment Landscape; and 3) new mobility.
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Meeting with Michalis Hadjipantela (Member of the European Parliament)

14 Jul 2025 · Introductory Meeting

Response to Recommendation on savings and investment accounts

8 Jul 2025

In the context of empowering citizens in their investment and savings choices, it seems essential to ensure that the instruments offered to them are in line with the nature of their investment objectives. Not all savings needs are equal: financing pensions, for example, requires a long-term strategy, with a controlled level of risk and rigorous time management without the need for liquidity or immediate interaction. However, current discussions about the promotion of savings and investment accounts through digital tools tend to blur this fundamental distinction between short and long investment horizons. Such confusion can lead savers to adopt products that are unsuitable for their plans and real savings objectives. It is therefore imperative that the design and regulation of these instruments take full account of the diversity of project temporalities and risk profiles. We therefore call on the European Commission to: - ensure regulatory consistency across all investment products, including online savings offers, to ensure investor protection; - promote active management, which helps to direct investments towards Europe and its major transitions; - ensure that its future proposals (label, accounts, etc.) take account of the diversity of existing and proven products in the various Member States; - learn from the mistakes of the past (cf. PEPP) and offer a flexible label that adapts to these products; - protect consumers of the dangers related to the gamification of investments. These requests are described in the document enclosed.
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Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology) and Veolia Environnement and

3 Jul 2025 · Exchange on cloud policies

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

23 Jun 2025 · Green transition investments

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

Aéma Groupe welcomes the opportunity to provide feedback and makes the following recommendations, detailed in the document enclosed: 1. Removing market barriers: The introduction of the European passport for funds has been an important step towards disseminating and distributing investment products throughout the European Union. However, disparities in investment rules persist, creating unequal conditions of competition between asset management players. The strengthening and harmonization of application procedures would therefore be necessary to unify the savings market and thus strengthen the Savings and Investments Union. For that Union to be effective, it is necessary to harmonize the operating rules of the various markets in the European Union, particularly with regard to the conditions under which issuers are listed on the stock market and the dialogue between investors and issuers. 2. Harmonising and strengthening shareholder democracy: At European level, a myriad of national regulations and obsolete case law are hampering the necessary development of shareholder democracy. In addition, the rules governing the percentage of shareholding required to propose resolutions have not been updated, while corporate mergers are creating giants and the amounts required to express opinions are becoming increasingly inaccessible to European investors. To make economic players more accountable, we are calling for the introduction of a harmonized framework at European level, requiring very large listed companies to answer investors' questions about the use of the savings entrusted to them. (more in the document enclosed) 3. Adjusting capital requirements: Deepening and integrating European capital markets requires an adjustment of capital requirements, which would allow insurers to play a bigger role in financing long-term investments. Currently, high capital requirements limit their ability to invest in a broader range of assets, including equities and infrastructure projects. Solvency II's excessive regulatory capital charges, including those related to equity investments, are indeed an obstacle to insurers' ability to invest for the long term. These charges should take better account of the long-term nature of the insurance sector and its impact on the real risks incurred. The delegated acts of the Solvency II review must be properly designed and calibrated to improve insurers' investment capacity, avoid procyclicality and ensure their competitiveness, while maintaining a high level of protection for policyholders. 4. Striking the right balance: clear and targeted information for retail investors: Providing clear, well-structured investment information is key to strengthen capital markets and ensure informed decision-making. The Key Information Document (KID) for PRIIPs must be refined (with the Franco-Czech proposal offering a reasonable approach), improving clarity without adding unnecessary complexity. Several RIS proposals should be reconsidered. A "sustainability section" is redundant, as sustainability data is already available elsewhere. Adding a dashboard would make the KID too long, diluting its effectiveness as a summary document. Likewise, retaining the comprehension alert across all KIDs removes its value, as it no longer serves a distinguishing purpose. KID should remain a standardized pre-contractual document rather than a personalized subscription document. It could optionally become an interactive digital tool with dropdown menus for better readability. This interactive tool should remain optional. Additionally, replacing prospective performance scenarios with historical performance data would align KID with its previous UCITS format, while allowing regulatory flexibility for different product types.
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Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

Aéma Groupe supports the creation of sustainable product categories as part of the revision of the SFDR (option 2). The establishment of sustainable product categories at EU level is key to tackling greenwashing and ensuring regulatory coherence on sustainable finance. A categorisation system harmonised with other existing regulations will avoid market fragmentation within the Capital Markets Union and facilitate the establishment of effective distribution mechanisms aligned with investors' sustainability preferences. In addition, readable categories will potentially improve the ability of professional and retail investors to assess the sustainability strategies and objectives of financial products. A new categorisation system should move away from the existing distinctions used in Articles 8 and 9 and instead focus on investment strategy and clear terminology that is binding on all. It should focus on whether a product actively contributes to clearly defined sustainability goals, supports the transition or aligns with other ESG strategies. Establishing clear criteria for these categories will simplify complex concepts while maintaining key common principles such as exclusions and the treatment of controversies, the definition of sustainable objectives, and thresholds to be respected. Despite the potential compliance costs for financial entities, refining the framework will significantly improve retail investors' ability to understand product outcomes. Each product category should be defined by distinct attributes and objectives, while maintaining common minimum requirements for different product types. In addition, a new sustainable category of "mixed objectives" should be included to take into account investment products that have multiple objectives without focusing exclusively on one of them. Product categories should remain non-exclusive, allowing for flexibility in classification. In the transition to this new system, the following aspects, detailed in the document enclosed, should be paid attention to: - Supporting measures for implementation - Addressing the current challenges of the SFDR (defining ambiguous concepts, improving and simplifying the PAI framework, etc.) - Harmonising sustainability reporting regulations - Improving the accessibility of information
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Meeting with Francesco Corti (Cabinet of Executive Vice-President Roxana Mînzatu)

25 Apr 2025 · Information exchange on the role of social economy actors

Meeting with David Cormand (Member of the European Parliament, Shadow rapporteur) and Athenora Consulting

14 Apr 2025 · End of life vehicles

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

28 Mar 2025 · Exchange on relevant developments

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Mar 2025 · The proposal of a Savings and investments union

Response to Savings and Investments Union

7 Mar 2025

Aéma Groupe welcomes the opportunity to provide feedback on the upcoming proposal for a Savings and Investments Union. This document enclosed details our key messages: 1. As insurers invest a significant share of savings in the productive economy, they are key players in achieving the objectives of the Savings and Investments Union. 2. Investment products, and in particular insurance-based products (IBIPs), must be promoted and encouraged as key vehicles for investment in the EU. 3. The specificities of insurance products need to be recognized and taken into account by EU policies. 4. Consistency and maximum regulatory harmonization should be ensured. 5. It is essential to remove the obstacles that prevent insurers from investing in productive, innovative companies. 6. Streamlining the flow of savings into asset management and facilitating sources of investment require simplified rules. 7. A stronger shareholder democracy will ensure sustainable growth and greater sovereignty. 8. Social economy entities should be included in the development of the Savings and Investments Union. Aéma Groupe stands ready to contribute actively to the success of this key initiative.
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Meeting with Pierre Jouvet (Member of the European Parliament)

27 Jan 2025 · Santé et prévention en Europe