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European Insurance CFO Forum

CFO Forum

The European Insurance CFO Forum (‘CFO Forum’) is a high-level discussion group formed and attended by the Chief Financial Officers of major European listed, and some non-listed, insurance companies.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Please note that this is a summary of our contribution - the full answer can be found in the annex. Insurers support the ECs ambition to use the EUT to steer investments towards transition-critical activities, but major weaknesses in the insurance KPIs mean they are not reliable investment indicators. Our experience shows that, for insurance, the EUT has created disproportionate reporting complexity without meaningful analytical benefits. As risk underwriters, insurers face major challenges. While the TSC for underwriting of climate-related perils are relevant, the current Underwriting KPI requires splitting premiums and counting only natcat-risk components, while the denominator includes all non-life premiums, including lines unrelated to adaptation. This method does not reflect how underwriting operates, mechanically understates insurers contribution to climate adaptation and may create an unfair disadvantage for (re)insurers. The following targeted adjustments are therefore needed: a) removing the premium-splitting requirement; b) excluding nuclear and gas activities from the relevant tables; c) reverting to the previous, intuitive segmentation between taxonomy-aligned, taxonomy-eligible but not aligned, and taxonomy non-eligible premiums; d) clearly positioning the EUT within CSRD/ESRS framework, e); revising the KPI definition to reflect the ratio of taxonomy-aligned premiums to taxonomy-eligible premiums. On TSC design we suggest: A targeted review of underwriting TSC to ensure consistency with wider EU initiatives and with the evolution of NatCat schemes in the EU. These includes revising concrete points on: a) Pricing rules; b) Flat-rate schemes; c) Product design and d) DNSH clarity. Finally, any amendments should avoid disadvantaging preparers that have already integrated current TSC and DNSH into their underwriting process and product offerings. As investors, insurers use the EUT to a limited extent to assess sustainable investments. Only about 15.5% of portfolios fall in scope because many key asset classes are excluded. The EUT also favours already green activities instead of transition investments, limiting insurers ability to reflect support for decarbonising sectors, and reliability is further weakened by missing sustainability data, unclear definitions and late guidance. On TSC design we suggest: - Revising TSC and DNSH on Real Estate (7.7), renovation of existing buildings (7.2), and renewable energy production (e.g. 4.1, 4.2) to improve the sector investment KPI performance. - Appendix A (DNSH Adaptation) should be reviewed to clarify the following: a) materiality basis; b) reduce and manage climate risk; and c) scope of perils.
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Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

The CFO Forum welcomes the European Commissions first Omnibus package, to simplify sustainability reporting and disclosure requirements while keeping core elements and sustainability objectives. Our experience, as both users and preparers, highlights that the EU Taxonomy Regulation has yet to add value for our sector, whilst creating significant reporting burden, most notably with the insurance underwriting KPI We recommend removing the insurance underwriting KPI, or at the very least suspending its application, providing the necessary time to thoroughly review the usefulness of the KPI. The first two reporting cycles of reporting this KPI have not proven to be useful for assessing insurers contribution to sustainability. In the short term, removing or suspending the disclosure of the KPI is the only viable option as itdoes not seem feasible to address its limitations in a comprehensive and meaningful way at reasonable cost. For the insurance investment KPI, we support the introduction of a reporting materiality filter, set at 10% of the KPIs denominator. Introducing a materiality can significantly simplify (re)insurers Taxonomy reporting by removing the obligation to report information which is not material for their business. This materiality filter should therefore be applicable at group level. It is important that it will be possible for insurers to apply the materiality filter without undue restrictions (including the specific reporting templates on performance and exposures to fossil gas and nuclear activities). Therefore, the EC should clarify for (re)insurers that, under the materiality threshold, where value of Taxonomy-eligible assets is below 10% of the KPIs denominator, they are not required to assess the Taxonomy-alignment of these assets. Equally, we welcome the exclusion of entities with fewer than 1000 employees from the denominator of the insurance investment KPI, which will improve the usability and meaningfulness of the reported KPI. We also welcome the proposed simplifications to the general reporting templates, which should be extended to the specific reporting templates on performance and exposures to fossil gas and nuclear activities (would propose keeping Templates 1 and 2 (or 3), and not 1 and 5 as currently proposed - this would be more meaningful for users). However, it remains unclear how non-material premiums/assets should be reported, as they are not included in the revised Templates in Annex X. It should be also noted that the proposed template still includes non-NFRD companies in the covered assets and this should be deleted, and that an undue reference to the GAR was included in Annex X. In addition to the materiality filter, the meaningfulness of the insurers Investment KPI can be improved by allowing inclusion of data from voluntary Taxonomy reporting, in the same table as the Taxonomy reporting from companies obliged to report. Insurers agree with the EC that companies should be allowed to report on activities which are partially aligned with the criteria for sustainable economic activities clarifications on how to account for those should be provided and the reporting templates should be adequately amended. While insurers welcome recognition of the need to simplify the DNSH criteria, this should also be extended to the Minimum Safeguards requirements for the qualification of Taxonomy-aligned activities. Equally, we stand ready to contribute to the upcoming review of the EU Taxonomys Technical Screening Criteria. Lastly, the ECs Q&A on Taxonomy reporting will need updating following changes to the Taxonomy and in doing so should ensure that they do not create additional requirements or complexity. Whether the EC intends to continue issuing new EC notice about the EU Taxonomy, it is very important to give preparers adequate time for dealing with it.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

10 Mar 2025 · Exchange of views on the Omnibus initiative, and on various reforms related to the insurance framework

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Feb 2025 · European Commission’s CSRD and Taxonomy omnibus simplification proposals