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Associazione Nazionale fra le Imprese Assicuratrici

ANIA

ANIA is the representative body for insurance and reinsurance companies in Italy.

Lobbying Activity

ANIA Urges Simplified EU Taxonomy for the Insurance Sector

4 Dec 2025
Topic — Review of the EU taxonomy environmental delegated act to simplify technical screening criteria.
Message — ANIA calls for substantial simplification of the technical criteria used to identify sustainable activities. They advocate for expanding the framework to include transition activities and aligning underwriting rules. The association also requests explicit recognition of national disaster schemes.123
Why — This would allow insurers to report higher sustainability KPIs and reduce compliance complexity.45
Impact — Environmental standards might be diluted by including activities with lower environmental impacts.6
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Meeting with Pina Picierno (Member of the European Parliament)

14 Oct 2025 · Discussion on the future of the sector and its EU-related policies

Meeting with Giorgio Gori (Member of the European Parliament)

14 Oct 2025 · Saving and Investment Union

Meeting with Raffaele Fitto (Executive Vice-President) and

14 Oct 2025 · Exchange of Views in the Insurance Sector

Meeting with Irene Tinagli (Member of the European Parliament)

14 Oct 2025 · Courtesy meeting

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur)

30 Sept 2025 · Securitisation Framework

Italian insurance association urges removal of hidden regulatory burdens

5 Sept 2025
Topic — The consultation concerns technical rules for insurance and reinsurance sector prudential requirements.
Message — ANIA requests a recalibration of the Volatility Adjustment and removal of the risk margin floor. They also seek to reduce operational complexity and shorten the equity holding threshold.123
Why — This would lower capital requirements and reduce administrative burdens for insurance companies.4
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Italian insurers call for simpler sustainable finance disclosure rules

29 May 2025
Topic — The European Commission is reviewing rules for disclosing sustainable financial products.
Message — ANIA requests a clear system to categorize products including transition options and defense investments. They also seek to reduce reporting indicators and protect existing products through a transition period.123
Why — Streamlined reporting requirements would significantly reduce the administrative burden and compliance costs.45
Impact — Investors could receive less detailed information if sustainability reporting indicators are reduced.6
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

13 May 2025 · - SIU is crucial - Importance of savings and investment accounts and main features - The financial lab seems a good initiative - FIDA and RIS negotiations - Solvency II Delegated Act

Italian Insurance Association Urges Lower EU Reporting Thresholds

26 Mar 2025
Topic — Amendments to simplify sustainability reporting and reduce data requirements for companies.
Message — ANIA requests a 10% eligibility threshold to exclude non-material assets from reporting requirements. They also seek a revised underwriting indicator and clearer timelines for new rules.1234
Why — This would significantly reduce compliance costs and lower the administrative reporting burden.5
Impact — Transparency suffers as narrowed reporting scopes worsen data availability and quality for users.6
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Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur)

25 Mar 2025 · Capital Market Union

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and Insurance Europe and

6 Feb 2025 · End of life vehicles

Meeting with Brando Benifei (Member of the European Parliament)

23 Apr 2024 · Discussion on priorities for EP's next legislature

Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

19 Feb 2024 · Solvency II review

Meeting with Fabio Massimo Castaldo (Member of the European Parliament)

24 Jan 2024 · Financial Data Access

Meeting with Fabio Massimo Castaldo (Member of the European Parliament)

6 Dec 2023 · Insurance recovery and resolution directive

Italian insurers urge clearer guidelines for sustainability reporting

6 Jul 2023
Topic — The European Commission is setting rules for corporate environmental and social reporting.
Message — ANIA requests official implementation guidelines and digital tagging formats as soon as possible. They also advocate for aligning sustainability reporting with financial market disclosure rules.123
Why — Standardized guidelines would help insurers avoid massive IT costs and personnel shortages.45
Impact — Investors face poor data quality and lack of comparability without clear rules.6
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

4 Apr 2023 · introductory meeting with Presidents of IT, FR and DE Insurance Assoc

Meeting with Paolo Gentiloni (Commissioner)

4 Apr 2023 · Exchange of views on the macroeconomic outlook and the role of the insurance sector in supporting the Capital Markets Union and long term investment

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

14 Feb 2023 · ANIA shared their concerns in relation to the upcoming Retail Investment Strategy and in particular in relation to the ban on inducements.

Meeting with Elena Lizzi (Member of the European Parliament, Shadow rapporteur)

5 Dec 2022 · Data Act

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

22 Jun 2022 · 1) Solvency II: state of the negotiations 2) Retail Investment strategy 3) AI and the insurance sector 4) Insurance Summit in Rome

Italian insurers seek consolidated rules and limited value chain scope

23 May 2022
Topic — New EU framework for corporate sustainability due diligence and long-term value creation.
Message — Focus on limited principles set in hard law combined with an extensive soft law regime. Require due diligence requirements to be applied only at consolidated level. Provide a specific definition of the value chain limited to direct business partners.123
Why — Consolidating reporting and avoiding new supervision layers reduces administrative costs and systemic complexity.45
Impact — Impacted communities lose protections if corporate responsibility does not extend beyond direct business partners.6
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Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur) and Assicurazioni Generali S.p.A and Unipol Assicurazioni S.p.A:

17 May 2022 · Solvency II review

Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Mar 2022

ANIA, the Italian Insurance Association, fully supports the proposal of the European Commission (EC) for establishing the European Single Access Point (ESAP), an EU-wide platform, to provide financial and non-financial information. The availability of quality, reliable, comparable, easily accessible, digital information is in general very important, but it is essential for ESG data. Creating an ESAP as a public good would not only decrease companies’ dependence on external data providers but, above all, it could increase the development of sustainable finance products and allow access to investments also for smaller entities. Therefore, while supporting the scope of the ESAP to cover both financial and non-financial data, ANIA believes that the highest priority should be given to ESG data needed under the CSRD, SFDR and Taxonomy, that should be available as of phase 1. Financial and other types of information can be incorporated at a later stage, following a phased approach. The sustainability information and the ESG data to be collected in the ESAP should: • allow to comply with the obligations already outlined in the SFDR, the Taxonomy Regulation and the upcoming CSRD; • guarantee quality, reliability and comparability taking into account the work underway at EFRAG level on sustainability standards; • build upon the information already available and collected by European and national institutions, such as governments, central banks, statistical bodies, etc; • avoid any possible duplication and redundancy of information, considering materiality and proportionality; • be in a standard digital format, to be easily accessible and usable, minimising the costs and the need to rely on third-party providers. A centralised electronic EU ESG data register, such as the ESAP, will not only allow complying with the above-mentioned disclosure obligations but will also help the insurance sector to fully play an essential role in fostering sustainability, providing robust ESG data to correctly identify sustainability risks and to facilitate the access to sustainable investments. In this respect, the access free of charge for the insurance sector should be guaranteed, in order to allow insurers to comply with the mandatory requirements imposed by the SFDR, the Taxonomy Regulation and the NFRD/CSRD. Insurers should therefore not be considered in the perimeter of “high volume users” which should pay a fee to access to the ESAP. Moreover, ANIA believes that a key point is timing. On the one hand, there should be an alignment between the timing of entry into force of disclosure obligations and that of data availability through the ESAP. On the other hand, the publication of the RTSs to be developed by the ESAs should allow sufficient time for an orderly and consistent data collection, thus guaranteeing uniform application and comparability.
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Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)

12 Jan 2022

ANIA appreciates the EC’s recognition of some important critical issues highlighted by the Insurance Industry in the stakeholder consultation, such as those related to the design and calibration of the Volatility Adjustment. These changes somewhat contribute to reflect, in aggregate, the reality of insurers’ business models and balance sheets and increase the effectiveness of the VA in mitigating artificial volatility. However, additional refinements are urgently needed to ensure a better alignment to the real risks faced by insurers and to allow the European Insurance sector to maintain its long-term business and products for the benefit of customers and financial stability and to play their full role within the sustainable transformation and other EU political objectives. In particular, ANIA calls for: • an appropriate valuation of insurance liabilities, which requires removing procyclical elements in the Volatility Adjustment to better mitigate market volatility, fully recognise country specific spreads within the eurozone and better reflect the spread above the risk-free rate that insurers can and do earn. • an appropriate, risk-based capital treatment of assets, which requires: o fixing the design of the long-term equity asset category; o allowing for negative interest rates in the capital charge calculation with an appropriate floor. Volatility Adjustment The procyclical nature of the new risk correction methodology proposed by EIOPA and brought forward by the EC severely restricts the ability of the VA to offset artificial spread volatility, thereby undermining the anti-cyclical effect of the VA. The removal of the AR5 in the EC’s proposal, indirectly reduces the procyclical effects which have emerged in the VA proposal contained in EIOPA’s advice. Nevertheless, the pro-cyclical effect has not been removed. To minimise the adverse effects described above and to maintain the VA’s ability to act as an effective countercyclical tool, the RC proposed by EIOPA should be amended by i) modifying the percentages becoming relevant in case the spread values exceed their long-term average (LTAS) and ii) defining an additional layer for the portion of the current spreads exceeding twice their respective LTAS. Interest Rate Risk module ANIA recognises the need to properly reflect extremely low and negative interest rates in the insurance regulation, thus recalibrating the IRR module to reflect the low and negative yield environment and welcomes the EC improvements with respect to the EIOPA’s proposal on the illiquid part of the curve. However, the proposed methodology may result in unrealistically large decreases in the liquid part of the curve. This should be addressed by including an explicit floor which reflects a realistic lower bound to interest rates. Long Term Equity module ANIA welcomes the introduction of an LTE module, but it should be further refined to: • adequately recognize the fundamentals of long-term investments • reflect the volatility in the equity markets • reflect market practices in the widest number of European countries. In particular, the requirement to build HRGs with at least 10 year liabilities, should be lowered to 5, a time period which already has a much lower volatility than a 1-year horizon. This would make achievable the LTE module in countries where business is characterised by lower durations such as Italy. Internal models The inclusion of the EC’s new requirements for internal model users (i.e. enhanced prudency principle) would increase the operational burden significantly for companies who use the DVA and would increase the, already high, costs of developing and maintaining internal models or undermine their usefulness. Moreover, it is not clear how these new requirements should translate into improved supervision and/or control on internal model features such as the DVA usage. ANIA believes that solutions need to be found to eliminate or reduce these additional new requirements.
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Meeting with Mairead McGuinness (Commissioner)

12 Oct 2021 · Pre-record speech on Sustainable Investment

Response to EU Standard for Green Bond

22 Sept 2021

GB STANDARD PROPOSAL – FEEDBACK ANIA ANIA welcomes the proposal for a European Green Bond standard as both the issuers and the investors would benefit from an improved transparency and a harmonization of the rules for the external reviewers. An EuGBS anchored to the Taxonomy Regulation would therefore help in achieving the EU sustainable finance goals of redirecting the investments to sustainable activities, thanks to the credibility of the denomination, thus reducing reputational risks and greenwashing and giving investors confidence in investing in green bonds. The EU GBS has the potential to become a global standard for green bonds. In a global capital market, the EC is encouraged to collaborate internationally with other jurisdictions on defining standards for non-European bonds. Nevertheless, given the more stringent requirements compared to the current market standards, and considering the EuGBS application is voluntary, it must be assessed what the final impact of the Regulation will be on the (green) bond market. With regard to the proposal, ANIA would like to suggest the following improvement: • Grandfathering: the current proposal suggests a partial grandfathering, where it states that if the Taxonomy criteria change after issuance, the amended criteria need to be applied within five years. We think investors should be assured that green bonds will be green till the maturity, so outstanding EU green bonds should not be affected by changes to the screening criteria of the Taxonomy.
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Response to Revision of Non-Financial Reporting Directive

21 Jun 2021

ANIA, the Italian Insurance Association, fully supports the CSRD proposal and its aim to significantly improve sustainability information and corporate sustainability reporting and welcomes the opportunity to provide some feedback. ANIA recognises that the CSRD proposal goes in the right direction of making corporate sustainability reporting more consistent, comparable and reliable. In this same vein, ANIA supports the EFRAG role in developing sustainability standards and the ESAP initiative, that will enhance the availability and accessibility of quality ESG data in digital format. These are key aspects for the Italian insurance industry, in its double role of preparer and user. ANIA would like, nonetheless, to give its contribution, providing some considerations on key aspects. Consistency and timeline: ANIA deems of the utmost importance to guarantee full consistency between CSRD and the broader EU sustainable finance framework, which comprises the SFDR and Taxonomy Regulation (TR), that have already introduced sustainability reporting requirements for the insurance sector. The consistency has to be assured at the double level of contents and timing. As for the contents, it is essential to avoid duplication and redundant reporting. Regarding the timing, the timelines of CSRD, SFDR and TR should be aligned. Moreover, differently from SFDR and TR, companies should be given sufficient time to prepare for new disclosure requirements. In this respect, ANIA notes that the timeline set forth by the Commission and EFRAG is very ambitious and there is a high risk of not leaving enough time for companies to adapt their internal systems and procedures. If this is the case, a delay of the entry into force of the CSRD may be warranted. Moreover, a phased approach should be considered in line with the standards that EFRAG will define. The first set of requirements should focus on reporting information as defined by the SFDR and the Taxonomy. Scope: ANIA welcomes the proportionality of the CSRD, especially for SMEs. Non-listed SMEs, in particular, should be encouraged towards a voluntary disclosure with a simplified and lighter regime, that would nonetheless provide users and investors – such as the insurance sector – with sustainability information and ESG data, necessary also to comply with SFDR and TR. In addition, attention should be given to preserve a level playing field – to the maximum extent possible - at the international level, with particular regard to non-European companies operating in the EU. Assurance requirements: ANIA welcomes the proposed assurance requirement, which should be only restricted to “limited assurance”. As for “reasonable assurance”, on the one hand, it is practically impossible in the absence of sustainability audit standards, and on the other hand, it may be considered only at a later stage – not automatically after the definition of audit standards - when the CSRD framework – also in terms of sustainability reporting standard - will be adequately implemented and tested. Role of EFRAG: ANIA welcomes the European Commission’s mandate to EFRAG to develop sustainability standards. It is undeniable that the European Union is already at the forefront in developing such standards. Therefore, any global initiative should take it as a reference in future works. Publication and language of the sustainability reporting: ANIA believes that the option to publish sustainability reports at a consolidated level should remain, to avoid additional burdens and costs. As for the publication requirements for subsidiaries of the parent’s sustainability reporting, the publication should be made in the language commonly used in finance, not leaving any option in this regard to the Member States, to preserve a level playing field throughout the EU.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Gesamtverband der Deutschen Versicherungswirtschaft e.V. and Fédération Française de l'Assurance

19 Nov 2020 · Address Webinar on Solvency II review

Meeting with Paolo Gentiloni (Commissioner)

22 Sept 2020 · Opportunities and solutions through insurance private sector to Covid economic crisis. State of the art and ways forward.

Meeting with Marco Piantini (Cabinet of Commissioner Paolo Gentiloni)

29 Jan 2020 · Sustainable mobility, EU green Deal

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

15 Oct 2019 · Solvency II review

Response to Amendments to the implementing rules on solvency applicable to insurers

6 Dec 2018

ANIA, the Association of Italian insurers, welcomes the opportunity to provide comments on the EC draft proposal for changes to Solvency II Delegated Regulation. In general, we share the comments on the various issues of the consultation drafted by Insurance Europe. Here we focus on a specific issue, which is crucial for the Italian insurance industry: the application of the Volatility Adjustment (VA), particularly as regards its “national component”. The VA aims at preventing procyclical investment behaviour and, for that reason, its outcome should be predictable in order to reduce the uncertainty for insurance undertakings. However, the erratic functioning of the VA has shown to be a major cause of uncertainty for the Italian insurance industry, as it has been recently pointed out by several CEOs at IVASS’s Conference on Solvency II review last October. While waiting for a comprehensive revision during the Solvency II Review 2020, we deem necessary to provide a short-term fix already in the Review 2018. Our position is fully consistent with the letter sent by the European Parliament to President Dombrovskis on September 18th. In the Appendix we clearly show that the VA did not work properly, at least in Italy, thus creating perverse incentives and complicating the monitoring of the evolution of an insurance undertaking solvency position in the continuous time, as requested by Artt. 44 and 102 of the Directive. In both Level 1 and Level 2 text there is no indication on how such activation should be verified. In particular, Article 77d(4) of the SII Directive states that: For each relevant country, the volatility adjustment to the risk-free interest rates referred to in paragraph 3 for the currency of that country shall, before application of the 65 % factor, be increased by the difference between the risk-corrected country spread and twice the risk-corrected currency spread, whenever that difference is positive and the risk-corrected country spread is higher than 100 basis points. Against this background it would be useful to have in the Delegated Acts clear guidance. The general objective is to clearly state that the national component of the VA at the end of a reporting period is activated whenever conditions set in Article 77d(4) are met at any-time during the reporting period. This is literally consistent with the Level 1 text. Such clarification would reduce uncertainty around the triggering of the national adjustment and avoid giving wrong incentives to insurers’ investment behaviour.It is now a matter of defining which value should be used for computing the national adjustment, once its activation has been verified during the reporting period. 1)Our preferred solution would be the one suggested in the letter from European Parliament to President Dombrovskis, which consists in considering the value at the end of each period as the highest value observed on a daily basis in that reference period. In this case insurance undertakings would know day-by-day the value to apply at the end of the period. According to the response letter by President Dombrovskis this is considered inconsistent with Level 1 text, possibly because it is generally accepted (but never affirmed) that all evaluations should be done at the last day of the period. 2)To overcome this objection, an alternative solution is to use directly the end of period value. To achieve this the following paragraphs should be added to the Delegated Acts (i.e. into Article 50 which contains the formula to calculate the spread underlying the volatility adjustment): Conditions referred to in Art. 77d(4) shall be considered as met if the specified criteria are met at least once during the reporting period, based on a daily calculation. Where these conditions are met during the reporting period, the volatility adjustment shall only be increased when the difference between the risk-corrected country spread and twice the risk-corrected currency spread is positive.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

14 Mar 2018 · Solvency II; PEPP; Sustainable finance; Motor Insurance Directive; ESAs Review

Response to DA on conduct of business rules for the distribution of insurance-based investment products

8 Aug 2017

With reference to Commission draft Delegated Regulation on information requirements and conduct of business rules applicable to the distribution of insurance –based investment products, please find herewith the comment from Italian Insurance Association (ANIA). We highlight the following point on IBIPs DA: the need to have a level playing field between UCITS and insurers on derivatives. This issue is that UCITS can invest in derivatives, subject to certain controls and limits, even though derivatives are not included in the list of non-complex financial instruments in MiFID II. Since Article 30(3)(a) of IDD refers to the list in MiFID II (and not for example to the rules in UCITS), in the case of funds managed by insurers these will be deemed complex products whenever derivatives are used. This is despite the fact that insurers are generally required under Solvency II to limit their use of derivatives to risk reduction purposes or efficient portfolio management (Article 132(4) of Directive 2009/138/EC). We should stress that the use of derivatives for risk reduction or efficient portfolio management purposes does not necessarily result in a product being deemed complex. An IBIPs can provide investment exposure to non-complex MiFID II financial instruments, but also uses derivatives for limited purposes and not as an investment strategy or for speculative purposes.
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Response to DA on product oversight and governance requirements for insurance undertakings and insurance distributors

8 Aug 2017

With reference to Commission draft Delegated Regulation on Product Oversight Governance for insurance undertaking and insurance distributors, please find herewith the comments from Italian Insurance Association (ANIA). 1. It’s really relevant that the possibility to sell outside of the target market should be clearly provided for by an article and not only by a recital. 2. We suggest to introduce the word “all” in art. 3 § 2 as follows: “A decision-making role shall be assumed, in particular, where insurance intermediaries autonomously determine all the essential features and main elements of an insurance product, including its coverage, price, costs, risk, target market and compensation and guarantee rights, which are not substantially modified by the insurance undertaking providing coverage for the insurance product.” In fact, we consider that a distributor have to determine all the essential features and main elements of the product to be considered as manufacturer. 3. We propose to insert in art.8§3 litt.c the words “where relevant” as follows: … 3. The information referred to in paragraph 2 shall enable the insurance distributors to: (a) understand the insurance products; (b) comprehend the identified target market for the insurance products; (c) identify, where relevant, any customers for whom the insurance product is not compatible with their needs, characteristics and objectives; (d) carry out distribution activities for the relevant insurance products in accordance with the best interests of their customers as prescribed in Article 17(1) of Directive (EU) 2016/97. ….. The requirement, together with the requirement to ensure that any contract is consistent with the customer’s demands and needs, makes it unnecessary to introduce any additional requirement regarding the specification of a negative target market. In any case, we ask that, at least, the decision be left to the discretionality of the manufacture. 4. On art. 13, we call that this article be in line with recital 13, as follows: …. “It shall apply from the entry into application of the national measures“ It is important to stress that the implementation date risks, in some Countries, to be different from the date of 23 February 2018.
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Meeting with Valdis Dombrovskis (Vice-President) and

13 Apr 2015 · Meeting with social partners