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Fédération Française de l'Assurance

France Assureurs

France Assureurs represents French insurance and reinsurance companies, covering over 99% of the market with 247 member firms.

Lobbying Activity

Meeting with Magdalena Andreea Strachinescu Olteanu (Head of Unit Maritime Affairs and Fisheries)

21 Nov 2025 · First introduction, exchange on common challenges/opportunities in mobilising blue economy investments

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis) and

18 Nov 2025 · Competitiveness and simplification

Response to Strategy on Intergenerational Fairness

10 Nov 2025

France Assureurs, fédération professionnelle représentant les entreprises dassurance et de réassurance opérant en France, accueille avec un vif intérêt la consultation de la Commission européenne sur la future Stratégie pour léquité intergénérationnelle. Dans cette perspective, France Assureurs souhaite souligner le rôle essentiel que joue le secteur en matière déducation financière, levier fondamental pour renforcer la résilience, lautonomie et la confiance des citoyens, conditions indispensables dune équité durable entre générations. Léquité intergénérationnelle ne se limite en effet pas à la répartition équitable des ressources, elle implique aussi un accès équitable à la compréhension des mécanismes économiques, financiers et assurantiels qui façonnent le quotidien des citoyens. C'est pourquoi nous détaillons dans le document ci-joint nos actions en matière d'éducation financière.
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Meeting with Pierre Jouvet (Member of the European Parliament)

27 Oct 2025 · Echange sur la gestion des risques et la filière assurantielle française

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

9 Oct 2025 · Address seminar of Fédération Française de l'Assurance

Meeting with Ion Codescu (Head of Unit Environment) and Global Federation of Insurance Associations

12 Sept 2025 · Insurance sector faced with increasing climate and environmental risks

Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

5 Sept 2025

France Assureurs expresses strong 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, we also raise concerns about certain provisions that may undermine these goals and add complexity without clear prudential benefits. In particular: 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. Finally, 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 the industrys 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 weight 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. 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. It is regrettable that these points were not subject to more in-depth discussions. 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. Internal models: Introducing artificial bias into internal models through the review such as the derecognition of capital contingent instruments, standard formula reporting or the application of the enhanced prudency principle when overshooting is already avoided would undermine one of the most significant risk management achievements of Solvency II. Minimum group SCR: The Commission is bound by the Level 1 text to specify the application of the group minimum SCR. It should clarify the elimination of the non-economic double counting of risks, which has no equivalent globally and would unfairly disadvantage European groups.
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French insurers urge EU to streamline data sharing rules

18 Jul 2025
Topic — EU strategy to create a coherent legal framework for data sharing.
Message — The group calls for pausing new financial data sharing laws. They prioritize streamlining existing rules over creating new regulatory burdens. They demand that data sharing obligations apply equally across all sectors.123
Why — Harmonizing rules would lower compliance costs for European insurance companies.4
Impact — Tech gatekeepers and foreign actors would lose access to strategic datasets.56
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France Assureurs urges EU to include insurance in savings plan

8 Jul 2025
Topic — A European Commission initiative to create a blueprint for Union-wide savings and investment products.
Message — The federation wants insurance and retirement products included in the new initiative. They argue the account concept is unsuitable and new labels will confuse citizens.12
Why — This approach ensures insurance products remain a primary choice for European household savings.3
Impact — Savers might find it harder to transfer funds because the group opposes portability.4
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Meeting with Maria Luís Albuquerque (Commissioner) and

23 Jun 2025 · Overview of the insurance landscape in France and presentation of France Assureurs

Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Jun 2025 · Investor’s round table

France Assureurs Urges Simplified SFDR Rules to Protect Euro Funds

28 May 2025
Topic — A review of EU sustainable finance rules to simplify reporting and prevent greenwashing.
Message — The federation requests reducing mandatory impact indicators and simplifying entity-level disclosures to avoid unnecessary burden. They also advocate for specific treatment of insurance 'euro funds' within categorization systems.12
Why — These changes would lower administrative costs and prevent the competitive downgrading of French savings products.34
Impact — Environmental groups lose detailed disclosures on biodiversity and energy consumption if these indicators become voluntary.5
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

14 May 2025 · Exchange on policy developments

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

6 May 2025 · SIU

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

28 Mar 2025 · The role of the insurance sector in achieving EU goals

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

28 Mar 2025 · Exchange with France Assureurs on the Savings and Investments Union and FIDA

France Assureurs urges simpler, more practical EU Taxonomy reporting rules

26 Mar 2025
Topic — Amending EU Taxonomy rules to simplify sustainability reporting and reduce company costs.
Message — France Assureurs requests deleting consolidated group KPIs and removing requirements to verify minimum safeguards for policyholders. They also seek clarifications on materiality thresholds and template alignment to ensure reporting reflects market reality.12
Why — These changes would significantly lower compliance costs and reduce the administrative burden of reporting.34
Impact — Investors could face data gaps if materiality filters are not properly balanced.5
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Response to Savings and Investments Union

6 Mar 2025

FRANCE ASSUREURSS VIEWS ON THE SAVINGS AND INVESTMENTS UNION France Assureurs fully supports the European Commission's objective of developing a Savings and Investments Union (SIU) to channel European households savings towards the real and sustainable economy of the European Union. I/ The insurance market is a major strategic asset of the EU The EU has a competitive, efficient insurance market with global champions and a high level of household trust to effectively protect their savings. European life insurance products offer guarantees and options tailored to all savers profiles, with a very protective legal framework and duty of advice at both European and national levels. Available through multiple distribution networks, these insurance products are designed with a long-term approach, allowing insurers to invest in a wide range of assets such as corporate and sovereign bonds, listed equities, real estate, as well as unlisted assets and private equity. The exposure to these various asset classes makes insurers key players in channeling household savings towards European assets, with nearly 9 trillion in assets under management, 82% of which are invested in the EU. II/ How to further direct European household savings towards financing the real and sustainable economy of the EU? The ambition of Savings and Investments Union must take into account the environments of the 27 Member States. Given the heterogeneity of savers' risk appetite, tax law and pension systems, France Assureurs advocates for a European label of savings products. This new labeling system will build on national products that have already gained public acceptance. This label would set requirements resolutely oriented towards long-term and sustainable financing of the EU economy, similar to the proposals made by the Noyer report, including: underlying assets benefitting the sustainable financing of the Union's economy; long-term investment horizon with withdrawal options limited to retirement and certain major life events; risk exposure without permanent capital guarantee. In return for these requirements, labeled products would benefit from the most attractive tax regime at the national level in their category. This initiative would have the advantage of: being quickly operational by relying on existing products; encouraging actors from all Union countries to develop savings products adapted to their markets and in line with the financing needs of the European economy. France Assureurs believes that the diversity of products, far from being a hindrance, is on the contrary an asset on which Europe must rely if it wants to effectively achieve the objectives set by the SIU. France Assureurs wants to signal that simple and low-cost savings products do not meet the objectives of the SIU, especially as market reality underlines that the assets backing such products do little to finance small and medium-sized enterprises and are mostly located outside the EU. III/ Need for coherence in all EU texts and initiatives All European initiatives and texts must be coherent with the objective of a SIU. In particular: Solvency II must further encourage insurers' long-term investments, notably by allowing a controlled revival of securitization to increase the depth of the private debt market. RIS should simplify European households' access to financial savings. Insurance supervision must remain national to be effective given the heterogeneity of Member States' environments and the low systemic risk that insurance represents.
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Meeting with Olivér Várhelyi (Commissioner) and Verband der Privaten Krankenversicherung e.V.

5 Feb 2025 · Mental health

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

5 Jan 2025 · Role of the insurers to achieve European competitiveness

Meeting with Eero Heinäluoma (Member of the European Parliament)

20 Nov 2024 · Current affairs relating to the insurance industry

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

22 Apr 2024 · capital Markets Union

Meeting with Geoffroy Didier (Member of the European Parliament)

12 Feb 2024 · Régulation du secteur assurantiel

Meeting with Laurence Sailliet (Member of the European Parliament)

12 Jan 2024 · Echanges autour des rapports Ris et FIDA

French insurers oppose scrapping cars based on repair costs

4 Dec 2023
Topic — Revision of EU rules on vehicle design, recycling, and end-of-life vehicle management.
Message — France Assureurs argues only technical criteria should define an end-of-life vehicle. They request removing economic criteria that force functional cars to be scrapped.12
Why — This allows insurers to manage rising repair costs and support the reused parts sector.3
Impact — Low-income households lose the ability to keep functional cars with minor cosmetic damage.4
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France Assureurs warns against rigid 30-day payment limits

7 Nov 2023
Topic — The consultation seeks to update EU rules regarding business payment delays.
Message — France Assureurs opposes the mandatory 30-day cap, calling it a violation of entrepreneurial freedom. They suggest focusing on stronger penalties and improved legal remedies instead.12
Why — Preserving flexible payment windows reduces the risk of widespread business insolvencies.3
Impact — Buying companies face liquidity shortages and may shift trade outside the EU.4
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France Assureurs demands extensive rewrite of open finance proposal

31 Oct 2023
Topic — This initiative proposes a framework for sharing financial data with third-party providers.
Message — France Assureurs argues the proposal needs an extensive rewrite to protect consumers and trade secrets. They advocate for cross-sector reciprocity and a longer implementation timeline than the current 18 months.123
Why — These changes would protect insurers' commercial secrets and prevent unmanageable infrastructure costs.45
Impact — High-risk consumers could face exclusion as data sharing encourages selective insurance coverage.6
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French insurers urge EU to regulate ESG raw data products

29 Aug 2023
Topic — A proposal to ensure transparency and reliability in the ESG ratings market.
Message — The federation calls for ESG raw data and other data products to be included in the regulation. They seek common standards and transparency to ensure data reliability for sustainable investment strategies.12
Why — Standardized data helps insurers meet reporting requirements and avoid greenwashing risks.34
Impact — ESG data vendors will face new transparency obligations, fee oversight, and conflict-of-interest rules.5
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France Assureurs warns against de facto ban on insurance commissions

22 Aug 2023
Topic — New EU rules aimed at increasing retail investor participation in capital markets.
Message — The federation insists that insurance intermediaries must be remunerated by commissions to guarantee access to advice. They also argue that the proposed implementation timeline for the new rules is too short.12
Why — Retaining commissions would protect the current business model of most French life insurance distributors.3
Impact — Small-scale investors could lose access to financial advice under the new commission rules.4
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French insurers urge alignment between sustainability and financial rules

7 Jul 2023
Topic — The Commission is defining mandatory sustainability reporting standards for large companies.
Message — The organization requests better alignment between standards and existing rules to resolve uncertainty. They propose making certain data mandatory while ensuring specific carbon accounting methodologies remain voluntary.123
Why — This would reduce compliance risks and simplify the collection of investor data.45
Impact — Investee companies would lose the flexibility to omit data points they consider immaterial.6
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Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

26 Jun 2023 · Data et Intelligence Artificielle

French insurance federation seeks one-year delay for green disclosures

2 May 2023
Topic — The consultation defines environmentally sustainable activities for water, circular economy, pollution, and biodiversity.
Message — The federation requests a one-year delay for mandatory disclosures because financial companies lack the necessary data from other businesses. They also propose simplifying reporting templates by removing non-applicable columns to improve clarity.123
Why — The delay and template changes would reduce immediate compliance pressure and administrative reporting costs.45
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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)

23 Mar 2023 · Follow up on Retail Investment Strategy

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

1 Feb 2023 · France Assureurs shared their concerns about the upcoming initiative on retail investment strategy and in particular on inducements ban.

Response to Review of the Designs Directive

31 Jan 2023

Please find attached a detailed position of French insurers regarding the revision of EU legislation on design protection. French insurers pay compensations for more than 7.5 million accidents involving material damages per year. Material damages represent approximatively 60 % of compensations paid out by insurers. Spare parts account for half of the total cost of repairs (i.e. about 30 % of total compensation amount). In France, visible parts on vehicles are protected under design and model or copyright law. Visible parts, registered after 1st January 2023, are protected for 10 years. It was introduced by a law adopted in 2021. As the average age of vehicles is 11.7 years, we do not expect any significant evolution on spare parts costs and prices. Visible parts, registered before this date, are still protected for 25 years. For almost 10 years now, French insurers have been seeing a steady and significant increase in the cost of automobile spare parts. According to the National Institute of Statistics and Economic Studies (INSEE) this increase was systematically stronger than inflation at least for the last 15 years. The increase reached the alarming rates of 6.5% in 2019 (compared to 2018), 8.1% in 2020 (compared to 2019), 4.6% in 2021 (compared to 2020) and 9.6% in 2022 (compared to 2021). The French insurance industry welcomes competition as a fundamental principle of the European Union and therefore strongly supports the liberalisation of the spare part market so to obtain a real effect on the cost of car repairs, especially through the introduction of a repair clause. Enhancing competition on the car spare parts market is an indispensable condition for controlling increases in the cost of repairs and would be a strong measure in favour of household purchasing power. However, the text of the proposal as currently drafted risks diminishing the effectiveness of the repair clause as it contains a 10-years derogation for parts that have already been registered and excludes key components such as wheel rims from the scope.. This could be especially problematic for a number of specific reasons: It could lead to legal uncertainty as it will be difficult for consumers, independent parts producers and repairers to know whether a particular car, mode or spare part l is protected. It could lead to de facto price discrimination as owners of older vehicles and low income will be penalised with high-priced visible spare parts, while new vehicle buyers will benefit from lower prices thanks to the new competitive market of visible spare parts. The deflation effect of the liberalisation of the spare parts market could be deterred as most of the repairs will still be subject to the old regime or directly excluded from the scope of the design package. Such a clause should apply to designs that are already registered as well as to all future designs without any spare part exclusion, to ensure legal certainty, as well as fair and effective competition and enhance consumer choice.
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France Assureurs Urges Legal Certainty for New Product Liability Rules

9 Dec 2022
Topic — The EU is updating liability rules for digital products and circular economy business models.
Message — The federation proposes limiting evidence disclosure and burden-of-proof presumptions to high-risk AI systems. They also call for clearer definitions and shorter liability windows for modified products.12
Why — These restrictions would reduce the risk of unpredictable payouts and ensure complex technologies remain insurable.34
Impact — Consumers injured by common products face harder paths to compensation without these evidentiary tools.56
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Response to Creation of the Common European Mobility Data Space

7 Dec 2022

Statement on the need for a sector-specific legislation on access to in-vehicle data By FRANCE ASSUREURS New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological transition and vehicle electrification. As with any digital technology, data represents the key component in these developments. As players of the mobility ecosystem, we welcome the Data Acts main goals: (i) the creation of a single market for data; (ii) the right for users to access the data generated by connected devices; (iii) the right to transfer access to such data to the third-party of their choice. However, as far as automotive data are concerned, we believe that while the access through third-party service providers is necessary and welcomed, it remains an insufficient step. To protect consumer rights and the innovative capacity of European undertakings, many use-cases will require direct access to in-vehicle data and resources. We are therefore convinced that a sector-specific legislation on access to in-vehicle data is required to complete the Data Act approach. If the European Union wants to foster innovation and see new players emerge in favor of more sustainable, shared and innovative mobility, it is essential that access to vehicle data is open to all relevant players, at the risk of creating distortions of competition and wasting time in the development of solutions that benefit European citizens. 1. All data, whatever their nature and subject to user consent, must be accessible in all fairness to all stakeholders. This also implies full transparency on the available data. 2. Vehicle users choices must be made truly effective through smooth processes for obtaining their consent. 3. Several access methods must be provided in order to preserve technological neutrality and avoid market foreclosures or gatekeeping mechanisms. 4. These accesses must take place under identical technical and economic conditions for all players, from the manufacturer to the independent operator. Financial conditions must be reasonable and compatible with the development of innovative digital services. 5. Access to vehicle data and resources (including the human-machine interface) must be direct and, when necessary, in real time (i.e., without delay). 6. Stakeholders must, as part of a business need, be able to access essential data stored in the electronic control units themselves. 7. A cross-sectoral and cooperative approach should make it possible to work towards a shared objective of vehicle security and cybersecurity. 8. European regulations are essential, particularly in terms of standards and interoperability, in order to establish these principles and neutral governance.
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French insurers demand alignment of AI liability and safety rules

28 Nov 2022
Topic — The European Commission is updating liability rules for damage caused by AI.
Message — It is essential to ensure rules are perfectly coordinated with other texts. The federation wants to maintain contractual freedom and avoid a compulsory insurance obligation. The scope of evidence disclosure should be limited to high-risk AI systems.123
Why — This would reduce compliance costs and prevent insurers from covering unpredictable risks.4
Impact — Victims of lower-risk systems lose simplified ways of proving damages under their proposals.5
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French insurance federation demands clear access to health data

28 Jul 2022
Topic — The European Health Data Space establishes a framework for sharing and accessing electronic health data.
Message — The federation calls for better definitions ensuring insurers can access health data for contract execution. They seek alignment with data protection rules to provide legal certainty for the industry.12
Why — Access to health data allows insurers to offer more affordable rates and assess risks.3
Impact — Ambiguity in the regulation could lead to legal disputes and reduce access to insurance.4
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French insurers urge protection of life insurance specificities and commissions

31 May 2022
Topic — EU initiative to enhance retail investor confidence and market participation across Europe.
Message — They demand a sector-specific approach for life insurance instead of treating it as a financial product. They advocate for commission-based compensation and leaving implementation methods to individual member states.12
Why — This protects the established French distribution model and avoids the costs of radical regulatory shifts.3
Impact — Lower-income savers lose access to advice if fee-only models replace commission-based structures.4
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France Assureurs urges excluding policyholder relations from due diligence

23 May 2022
Topic — The consultation addresses proposed EU rules on corporate sustainability due diligence obligations.
Message — France Assureurs wants to exclude insurance contracts from the scope of due diligence requirements. They request reporting at the parent company level and better alignment with existing financial rules.12
Why — This approach would protect their revenue by avoiding mandatory contract cancellations and reducing compliance costs.3
Impact — Employees and damage victims lose out if insurers stop providing essential coverage and protection.4
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

12 May 2022

10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological transition and vehicle electrification. As with any digital technology, data represents the key component in these developments. As players of the mobility ecosystem, we welcome the Data Act’s main goals: o the creation of a single market for data; o the right for users to access the data generated by connected devices; o the right to transfer access to such data to the third-party of their choice. However, as far as automotive data are concerned, we believe that while the access through third-party service providers is necessary and welcomed, it remains an insufficient step. To protect consumer rights and the innovative capacity of European undertakings, many use-cases will require direct access to in-vehicle data and resources. We are therefore convinced that a sector-specific legislation on access to in-vehicle data is required to complete the Data Act approach. If the European Union wants to foster innovation and see new players emerge in favor of more sustainable, shared and innovative mobility, it is essential that access to vehicle data is open to all relevant players, at the risk of creating distortions of competition and wasting time in the development of solutions that benefit European citizens.
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Meeting with Gilles Boyer (Member of the European Parliament)

22 Apr 2022 · AML package (staff)

Response to Minimum level of taxation for large multinational groups

4 Apr 2022

Please find here attached France Assureurs' feedback.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

28 Mar 2022

Please find attached the comments from France Assureurs (brand name of Fédération Française de l’Assurance). France Assureurs represents the views of French insurance and reinsurance companies, totalling more than 99% of the premium income of the French insurance market.
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Response to EU Anti-money laundering supervisor

18 Nov 2021

FFA is of the opinion that AMLA could promote better coordination of national authorities and guarantee a harmonized application of AML/CFT rules within the Union. Nevertheless, crucial issues are determined at Level 2 (e.g., entities subject to direct supervision). Regarding the direct supervisory powers given to the AMLA, FFA call for more details to be provided at Level 1. Please find attached the full FFA Position Paper for detailed comments on the AML Package.
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Response to Revision of EU rules on Anti-Money Laundering (recast)

18 Nov 2021

FFA welcomes the objective of strengthening the fight against money laundering within the EU, but it is important to ensure a level playing field for undertaking within the EU AML/CFT framework and to minimise costs related to central registers data. To ensure a harmonized AML framework at the EU level – as announced by the Commission, any decision regarding the extension of the scope should be decided at the EU level. Please find attached the full FFA Position Paper for detailed comments on the AML Package.
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Response to Revision of EU rules on Anti-Money Laundering (new instrument)

18 Nov 2021

FFA welcomes the objective of harmonization pursued by the EC, however, it is important to ensure that the shift toward a more integrated EU AML/CFT framework should consider that in France, the insurance sector is already subject to an extensive AML/CFT framework which already reaches purposes of the new proposals. Please find attached the full FFA Position Paper for detailed comments on the AML Package.
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Response to Requirements for Artificial Intelligence

6 Aug 2021

The French Insurance Federation (FFA) supports the implementation of a framework for an ethical use of AI: human-centric, unbiased, transparent, and explainable. French insurers welcome the Commission's proposal for a risk-based regulatory framework with differentiated rules according to the risks presented by AI uses that makes it possible to encourage technological innovation, while guaranteeing European values. However, FFA believes that the introduction of a regulation establishing harmonized rules on AI requires very clear and precise definitions of its concepts: the definition of an AI system, the notion of negative impact and its difference with the notion of fundamental rights infringement as well as the actors of AI. Indeed, on this last point, insurers insist on the need to clearly define the role of each actor in the AI value chain to better identify the responsibilities of each one of them. FFA is grateful for the opportunity to share their views and contribute to the European Commission consultation. On the classification of high-risk AI systems - A relevant classification of high-risk AIs is essential to ensure that the activities of private companies providing essential services are not inappropriately impaired - Need to clearly define several concepts and criteria used for the assessment as the notion of impact on fundamental rights as well to distinguish it from other potential negative impact. On the obligations of AI operators - The criteria for transparency should be defined more precisely. The notion of explicability should be given priority in the regulation. - It seems important that the user is informed that he interacts with an AI system (e.g. chatbot) and have the choice and the possibility to be redirected to a human. - Human control must be adapted, i.e. carried out by technical profiles but also business profiles or new specialized professionals and done in a proportionate way (e.g. by sampling) to not lose the benefits of automation, obtained through AI. - Error-free datasets requirement is disproportionate and unworkable in practice. - Recording keeping obligation needs to be clarified (terms, duration, etc.) and to consider practical impossibilities (e.g. versioning data). - Access to the source code of AI systems requirement should be reviewed for cyber security reasons; traceability or explicability requirements seem more proportionate and relevant. Other comments - It is necessary to articulate the proposal with European texts relating to data that already exist or are under discussion as well as with supervisory bodies competences in order to ensure the complementarity of these texts to avoid contradictions or overlapping obligations. - FFA is in favor of labels for AI systems but is concerned about the articulation of these new certification requirements with the standardization tools already in place, the cost that this may have and the workload that it will generate for the labelling of each AI system. EU should focus on a clear, simple, and workable labelling system and propose the labelling of AI development processes. - FFA welcomes self-assessment compliance and third-party compliance schemes for certain types of AI. Self-assessment should be based on common basic criteria. In conclusion, insurers are convinced that a certain number of existing rules already allow the use of AI to be regulated, but that the Artificial Intelligence Act can give more clarification, provided that it does not slow down innovation and the adoption of AI by European companies as well as not add a disproportionate additional layer of regulation introducing irrelevant obligations. However, it is necessary to consider the extensive legislative framework already regulating the insurance sector. Finally, EU must pay attention to maintain proportionality in the regulation in order to make Europe a pole of excellence and trust in AI (e.g. risk of becoming less efficient than other countries outside EU.)
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Response to Revision of Non-Financial Reporting Directive

13 Jul 2021

The French Insurance Federation (FFA) welcomes the proposal on a Corporate Sustainability Reporting Directive (CSRD). The newly suggested framework is highly relevant. French insurers particularly approve: - The concept of double materiality and the fact the CSRD encompasses the broad spectrum of sustainability topics (ESG pillars). - The extension of the scope to cover a wider part of the investment universe. - The development of EU non-financial standards and the mandate given to EFRAG to develop draft standards. - The requirement for the first standards to include the data needed for Taxonomy and SFDR reporting. - The requirement to tag and ensure machine-readability of sustainability information. - The option of publishing the sustainability statement at the consolidated group level. In this respect, the following key success factors should be considered in the upcoming process of sustainability standardisation: 1) Global cooperation on sustainability standardisation is key to reach convergence The FFA strongly supports the European Commission’s ambition to develop EU sustainability reporting standards in a constructive two-way cooperation. We invite the EU to work closely and collaboratively with existing standard setting initiatives, including the IFRS Foundation, to reach convergence as much as possible. 2) A well-balanced governance for the European bodies in charge of sustainability standardisation o FFA welcomes the mandate given to EFRAG to draft EU sustainability reporting standards. o Both preparers and investors are key stakeholders who should be well represented in EFRAG’s governance. o Financial services, in particular the insurance industry as the largest institutional investor in Europe, should be represented on the Board. This is even more essential as they are doubly involved, both as providers of non-financial reporting and as institutional investors. 3) Funding for the sustainability standardisation should reflect the EU’s ambition We also strongly believe that the financial resources for EU sustainability standardisation must match the declared ambitions. The resources provided by the EU for sustainability standardisation should be comparable to the support given to accounting standardisation to have a chance to meet the ambitious timeline and to be considered in the global standardisation process. 4) A clear and consistent articulation between the sustainability statement in the management report and the ESG data register in the ESAP is needed Trying to meet all the needs of all stakeholders in the sustainability statement would be at the detriment of the conciseness and meaningfulness of the reporting. Issuers should keep flexibility to choose the most relevant indicators to disclose in their sustainability statement in the management report, based on their materiality analysis. Indicators that are not considered material by the undertaking should however be disclosed in the ESAP. 5) An ambitious timeline with a proportionate approach o If the finalization of the standards takes longer than expected, the timetable will need to be adjusted to allow sufficient time for preparers. o The principles of progressivity and proportionality should guide the work on the European standard-setting. For instance, the reporting on intangibles is not mature enough to be compulsory or framed through standardization. o All undertakings newly falling into the scope should be given a delay (not only SMEs but also large undertakings between 250 and 500 employees that will enter in the scope for the first time). o Regarding assurance, we welcome the proposal to audit the data disclosed on a limited assurance basis. Ideally, at a later stage it would be more comfortable for investors to have a reasonable assurance. However, a decision should not be made to automatically move to reasonable assurance without a sound cost benefit analysis.
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Meeting with Pascal Canfin (Member of the European Parliament) and WWF European Policy Programme

24 Jun 2021 · Green finance

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The French Insurance Federation (FFA) appreciates the possibility to provide comments to the EC draft proposal for a Delegated Act under article 8 of the Taxonomy Regulation. The FFA is supportive of the suggested insurance KPIs and appreciates the fact that: - Sovereign exposures are excluded from the investment KPI ; - The KPI numerator for underwriting activities, based on premiums, can be assessed at product level. The industry sees some need for further refinement to ensure the disclosures are fully meaningful and efficient for information users, while achieving consistency with ongoing work on sustainable finance. With respect to the investments KPI: • Methodologies for entity-level KPI under the CSRD must be consistent with the SFDR RTS on taxonomy-related product disclosures currently under development by ESAs. • The denominator of the main investment KPI should be based only on taxonomy-eligible investments where the insurer controls the investment decision. This means the following investments should be excluded from the nominator and denominator of the main indicator: o Sovereign, supranational and agencies (SSA) bonds other than green bonds as already suggested in the draft delegated act o Investments where policyholders make the choice of where to invest. This exclusion would provide a more accurate picture of the share of investments where the insurers are responsible for the investment allocation o Exposures to undertakings for which the data on Taxonomy-alignment is not available (because the undertakings are not subject to the CSDR or are from non-EU countries or do not publish the data because they are a subsidiary and the KPI is reported in a consolidated way at group level, etc.) o Derivatives, as they are not usually directly connected to an economic activity under the taxonomy and their inclusion is likely not to bring significant added value to information users. • The proposed progressive timeline with a first reporting only based on eligible and non-eligible activities is welcome and will help undertakings to implement the necessary IT, data collection, validation and management processes. However, for financial undertakings, the first full reporting should be in 2024 based on year 2023 to enable to use the complete data published by non-financial undertakings in 2023. • The French insurers welcome the fact that the Commission shall review by 1 January 2025 the application of this regulation and assess the needs of amendments regarding the inclusion of sovereign exposures as these assets are extremely relevant for insurers. With respect to the underwriting KPI: • The FFA is concerned that the proposed KPI will not reflect fairly neither the size of the actual taxonomy compliant activities of insurance undertaking nor the transition that could be undertaken toward fully compliant activities as regards climate change adaptation. This could lead to misinterpretation and misleading conclusions, detrimental for the sector. • The denominator should be based only on insurance products (other than life insurance) that include the underwriting of climate related perils and related to the LOBs mentioned in the Annex of the Climate DA Chapter 10.1. Therefore, the relevant KPI should be: GWP of taxonomy-aligned activities (ie. Products including the underwriting of climate related perils that comply with the technical screening criteria) / GWP of taxonomy eligible activities related to the LOBs mentioned in the Annex of the Climate DA Chapter 10.1 and covering climate risks. • The DNSH columns should be removed as the reporting of taxonomy-aligned activities already include, by definition, the assessment of the DNSH. The FFA has detailed these comments in the joint position paper and suggests an alternative template for the underwriting KPI for non-life insurance and reinsurance undertakings to better reflect the underwriting insurance alignment.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

30 Apr 2021 · Solvency II review

Response to Revision of the NIS Directive

18 Mar 2021

The French insurance sector welcomes the European Commission’s willingness to strengthen the level of cybersecurity across the Union as it has been identified by our industry as a major challenge. A clarification of the interaction between NIS2 and DORA is however needed to allow for a harmonised framework across Europe. This clarification should enable all elements of the insurance industry’s digital operational resilience to be solely regulated under the DORA, further to the lex specialis clause outlined under Article 1.2 DORA. FFA has prepared a document attached that unfolds its position regarding the revision of the NIS directive.
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Response to Digital Operational Resilience of Financial Services (DORFS) Act

23 Feb 2021

Please find attached French insurers' position on the DORA.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

9 Feb 2021 · Financing of green transition; climate adaptation

Response to Review of the Community Designs Regulation

12 Jan 2021

COMMENTS OF THE FRENCH INSURANCE FEDERATION (FFA) The French Insurance Federation (FFA) welcomes the Commission’s review of the Design directive and Community Design Directive. The objective set in the impact assessment to fully liberalise the aftermarket of spare parts, particularly in the automobile sector, constitutes the right answer to the developments observed by French insurers. French insurers pay compensations for more than 7.5 million accidents involving material damages per year. Material damages represent approximatively 60 % of compensations paid out by insurers. Spare parts account for half of the total cost of repairs (i.e. about 30 % of total compensation amount). In France, visible parts on vehicles are protected under design and model or copyright law. For more than five years now, French insurers have been seeing a steady and significant increase in the cost of automobile spare parts. According to the National Institute of Statistics and Economic Studies (INSEE) this increase was systematically stronger than inflation at least for the last 15 years. The increase reached the alarming rates of 6.5% in 2019 compared to 2018 and for the first 9 months of 2020 it increased by 7.3% compared to the first 9 months in 2019. In addition, Insurance Europe, the European federation of insurers, was carrying out a comparison of the prices of certain bodywork parts in several European countries until 2016. It emerged that the price of certain bodywork parts was 20 to 50% more expensive in France than in other European countries. The French Competition Authority stated in a 2012 report that various converging studies concluded that the removal of protection for visible spare parts would lead to a drop in the average price of visible parts of around 6 to 15%. These high prices are largely due to the de facto monopoly of car manufacturers in this closed market. Their increase is, among other cost increases borne by insurers (as inflation of compensation of bodily injuries), necessarily taken into account in the price of car insurance, which is a constrained expense for most households. Enhancing competition on the car spare parts market is an indispensable condition for controlling increases in the cost of repairs and would be a strong measure in favour of household purchasing power. Although insurance companies cover most costs related to accidents, more than one insurance taker out of three has not opted for comprehensive coverage thus having to pay for damages suffered. Additionally, depending on severity of damages, some insurance takers choose to bear the repair costs themselves in order to avoid a claim report and the financial drawback of a malus. Thus, liberalisation would directly benefit to consumers in all these cases. The French insurance industry welcomes competition as a fundamental principle of the European Union and therefore strongly supports the liberalisation of this market so to obtain a real effect on the cost of car repairs, especially through the introduction of a repair clause into the Design Directive.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The FFA welcomes the adoption of the EU as well as the inclusion of non-life insurance as an enabling activity contributing to adaptation to climate change for insurance activities that cover climate-related hazards. Non-life insurers, as risk managers, risk carriers and investors, have been taking sustainability considerations into their business for long time by insuring crucial infrastructure, buildings and people against natural catastrophes. Regarding the objective of adaptation to climate change, French insurers believe that current screening criteria do not accurately reflect the reality and specificities of our business model. We strongly recommend the Commission to review these criteria before the adoption of the delegated act. Relevant adjustments can be made without reducing the Commission’s ambition, in order to clarify and remove uncertainties for the eligibility assessment. Firstly, we note that listed criteria will apply at product- as well as company-level. This makes it very difficult to assess the criteria. Therefore, non-life insurers urge the Commission to only include company-level criteria. Secondly, inclusion of preventive and adaptation measures in insurance activities covering climate-related perils is more impactful than price signal or risk-based monetary rewards, as drafted in this delegated act. French insurers deem that it is prejudicial to link the insurance activities eligibility to price incentives. In France, the premiums for some products included in the EU Taxonomy are set by law (climate-related perils covered by the “CatNat” scheme). Thanks to this “catnat” scheme, all French people can be insured against cat nat. Besides, risk-based rewards and lower premiums criteria go against the principle of risk-based premiums’ calculation that already includes all implemented preventions measures. Therefore, we suggest removing the sub-criterion linked to “price signal” in criterion n°1 and extending criterion n°2 to all prevention or protection measures put in place by insurers, whether individual or collective, linked or not to the product. Indeed, such measures are at the very heart of insurers’ contribution to the objective of adaptation to climate change. Last but not least, regarding the data sharing criteria, we acknowledge the importance of sharing loss data to enhance adaptation to climate change with public authorities and/or academics. Many French insurers already contribute significantly to this end by sharing data with the French “Mission Risques Naturels”. However, as data is business sensitive and the intellectual property of insurers, the obligation to share the data individually with non-defined external parties free of charge is not appropriate. In order to meet this criterion, insurers should be able to anonymise the shared data, and to collectively fulfil this obligation. The FFA has detailed its position on this delegated act in the attached document. Please, find there our detailed comments and suggestions for adjustment of criteria. In conclusion, the FFA supports the inclusion of non-life insurance as an enabling activity contributing to the objective of adaptation to climate change. However, the FFA deems that the Commission should adapt some screening criteria to better reflect the reality of insurance activities, to not discriminate the French Market (where the majority of premiums are regulated by law for climate-related perils covered by the “CatNat scheme”) and to clarify and secure the eligibility assessment.
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Response to Review of the VAT rules for financial and insurance services

19 Nov 2020

The French Insurance Federation is grateful for the opportunity to comment on the enclosed roadmap for a review of VAT rules applicable to financial and insurance services. The industry fully supports the initiative for a global review of current applicable VAT rules. It is indeed of major importance for the industry that the growing legal uncertainty in the interpretation of VAT rules applicable throughout the EU market should be addressed. The VAT rules that are applicable to insurance services should be clear, efficient and easy to implement with the least possible occurrence of irrecoverable VAT issues or distortive side-effects of any new set of rules. Besides, as the 2017 CJUE case law has upset long-established partnerships patterns, the industry approves the idea that the European Commission would consider reintroducing the VAT exemption on cost-sharing agreements for financial and insurance services. Therefore, the European Commission assessment of a change in the VAT rules for the financial and insurance services is much awaited. Given the two policy options underlying the EC impact assessment, we insist the review should consider the following comments: (i) any new set of VAT rules should have a very clear scope, that includes all transactions contributing to the provision of insurance services, such as introductory services provided by qualified intermediaries, claims-handling or any other insurance-related services; (ii) in case the review should lead to the repeal of the VAT exemption on insurance services, the new regulation should not result in higher costs of implementation than abiding by the current VAT rules. Thus, such regulation revision should also include the repeal of IPT and parafiscal levies applicable to insurance transactions as well as any other tax applicable to insurance companies as substitutes for VAT. Furthermore, there should be a clear distinction in the scope of a VAT implementation on insurance services between transactions contributing to life insurance and those contributing to general insurance activities. In that respect, the introduction of a VAT liability should not disrupt the market; (iii) should the EC lean towards a limited removal of the VAT exemption on financial services, insurance excluded, then remedying provisions should also be included in the package to prevent higher amounts of irrecoverable VAT as financial services are a major input for insurance services. The French Insurance Federation will gladly contribute in any way to the next stages of the review of EU VAT rules for financial and insurance services. François Tallon French Insurance Federation Deputy Director Tax Affairs
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Gesamtverband der Deutschen Versicherungswirtschaft e.V. and Associazione Nazionale fra le Imprese Assicuratrici

19 Nov 2020 · Address Webinar on Solvency II review

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

The French insurers welcome the adoption of the first EU classification for sustainable economic activities deeply needed to increase sustainable investments. The French Insurance Federation (FFA) consider the delegated act as a useful guidance for all stakeholders, and this IIA is welcomed as it reflects the objectives of the Taxonomy Regulation. Seizing the opportunity of this roadmap consultation, the French insurers would like to flag a specific issue. Insurers are targeted by this regulation as investors. However, they may also be involved as companies providing insurance services, including non-life services. In this context, they may publish information on how and to what extent their activities are associated with the Taxonomy. Among the objectives, the delegated act aims at defining the relevant indicators for financial undertakings under the Non-Financial Reporting Directive (NFRD) (i.e., large banks and insurance companies). The FFA highlights the need to align these indicators required under the NFRD (article 8 of the regulation) with the technical screening criteria that will be defined to qualify the alignment of insurance activities under the Taxonomy (article 11 of the regulation). In March 2020, the Technical Expert Group (TEG) identified non-life insurance as an enabling activity contributing to the objective of adaptation to climate change. The French insurers are fully mobilized to contribute to this objective. However, they are not aligned with the eligibility criteria formulated by the TEG: “Non-life insurance eligible for the Taxonomy includes selected LOBs and insurance products and services that provide cover for climate-related hazards to activities and/or assets that are Taxonomy aligned”. French insurers cannot support this proposal: 95% of insurance policies are contracted by micro and small businesses that are not under the scope of the Taxonomy regulation and will not publish the green share of their turnover. This will mean an extremely burdensome assessment process for insurance companies to check if their clients qualify or not under the Taxonomy. It will only reflect the alignment of the market with the Taxonomy and not any supporting insurers’ policy to accompany their clients towards "green" activities. The FFA suggests the following alternative indicators, that seems appropriate to reflect the contribution of the non-life insurance activities to the objectives of adaptation to climate change and mitigation to climate change. 1/ Premiums of insurance products covering climate-related hazards as “green turnover” of non-life insurers: Non-life insurance could be eligible as an activity contributing to the adaptation objective as long as insurance product cover climate-related hazards. Climate risk insurance directly reduces the impact of natural disasters by covering the economic losses. Combined with prevention measures, it helps to reduce future climate-related hazards. Non-life insurance could therefore be considered as contributing substantially to adaptation to climate change, regardless of the sector of activity or assets covered, whether or not they are aligned with the Taxonomy. 2/ Expenditures on prevention/protection could illustrate the contribution of insurance to the objective of mitigation (via loss reduction) and adaptation of climate change (via climate risk prevention): By reducing the losses, prevention helps to limit the resources consumption needed to repair or replace insured properties and assets. Moreover, individual or collective climate risk prevention/protection measures contribute directly to the policyholder’s adaptation to climate change. Thus, a specific indicator could be prevention expenditures dedicated to climate risks. It is specific to insurers activities and it illustrates very concretely their direct contribution to the first two objectives of the Taxonomy.
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Response to REFIT review of the Motor Insurance Directive

24 Jul 2018

Dear Sir / Madam, Please find attached the comments of the French Insurance Federation (FFA) on the REFIT review of the Motor Insurance Directive. We remain at your disposal for any further information. Yours sincerely, Antonin Nonis Policy Adviser in EU affairs
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Response to Review of the European Supervisory Authorities

12 Jan 2018

General comments The French Insurance Federation (FFA) welcomes that the European Commission’s proposal for a review of the European system of financial supervision recognises the need for sector-specific responsibilities and expertise, which has been demonstrated in the past few years, and maintains EIOPA as a stand-alone authority, responsible for both prudential and conduct of business. FFA has always been supportive of the creation of a harmonised EU supervisory framework with efficient EU authorities, liaising closely with national supervisors (NCAs), in order to contribute to the stability and effectiveness of the financial system that delivers positive outcome for consumer protection across the EU. We also would like to recall that the main and key role of EIOPA is to ensure a consistent and sound application of the Solvency II framework at NCAs level (this also includes for instance construction insurance and medical insurance). Nevertheless, since the current structure of the European supervisory authorities has only been in operation since 2011, and Solvency II has only been in force for less than one and a half years, we hold the opinion that further assessment is needed before drawing conclusions which may result in substantial changes. In this context, we are calling on European decision-makers to adopt a cautious, pragmatic and well-thought approach with regard to an extension of EIOPA’s tasks and powers, in order to avoid any unintended consequences that may result in a lack of stability. Rather than considering new powers, existing tools and powers should be fully used and resources adequately assigned towards a proper enforcement of Solvency II. In addition, we would like to stress the importance of NCAs in the day-to-day supervision of financial institutions. NCAs have been developing an extensive knowledge and experience of market practices and products, enhancing their prominent role in the direct supervision of undertakings. EIOPA’s role is to ensure the convergence of supervision practices as well as a convergent application of the EU regulation resulting from a political decision of the co-legislators. We believe that a clear distinction between EIOPA’s role in ensuring supervisory convergence and EIOPA’s regulatory powers is needed. Lastly, we strongly feel that the European Commission’s proposal does not fully address the need for adequate transparency, nor provides all the required checks and balances. In this context, the execution of EIOPA’s tasks and powers must comply with the principles of better regulation, as well as with the need for EIOPA to demonstrate the added-value of EU initiatives, with due regard to the principles of subsidiarity and proportionality. We strongly believe that EIOPA’s mandate must take into account the competitiveness of the EU supervisory and regulatory framework, and seek to avoid any duplication, inconsistencies and unnecessary compliance burden for financial institutions. Please refer to the attachment to access our full position on the Review of the European Supervisory Authorities.
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Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

6 Dec 2017

The French Insurance Federation (FFA) welcomes the opportunity to comment on the cybersecurity package. The insurance industry is closely following the developments related to cybersecurity at EU level, in particular with regards to the increasing extent of cyberattacks and their impact. Insurers play an essential role in terms of risk mitigation and prevention, the latter being a key element of risk transfer to insurers. FFA welcomes this new initiative which represents a new step since the adoption of the NIS Directive and the GDPR towards building a resilient Europe vis-à-vis cyber threats. More specifically, FFA would like to stress its support to the strengthening of the role and mandate of ENISA. We believe that a permanent mandate and reinforced tasks would bring concrete added-value and are prerequisites to the development of an EU response to cyber risks which are by nature cross-border. The ENISA’s support to the reinforcement of Member States capacities as part of the implementation of the NIS Directive is a good example of this added-value. The French insurers also positively see the development of a cybersecurity certification framework. The implementation of such a framework for ICTs is key to protect economic stakeholders and strengthen EU consumers’ trust in digitalisation. However, this remains conditional to a series of criteria to be met in order to be successful. As key actors of cyber risks mitigation, the French insurers would like to take the opportunity of this consultation to also share further thoughts on this issue. FFA considers that cyber hygiene is essential to tackle cyber issues. Developing education and training initiatives, as proposed in the cybersecurity package via the implementation of annual safety exercises, would indeed be a very efficient driver of risk mitigation to the benefits of both consumers and insurers. In this regard, FFA has already developed tools such as a booklet to raise small and medium businesses’ awareness of cyber risks and good cybersecurity practices. The efforts should thus be pursued in this matter. Regarding the cybersecurity certification framework, FFA recognises that it would allow to create a common understanding of cyber risks between Member States. This European framework should nevertheless respect the current certification frameworks already in place in certain Member States, such as in France and Germany, and should not be less ambitious than already existing standards. In the meantime, certification requirements should be enforceable in all Member States to ensure its success.
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Response to REFIT review of the Motor Insurance Directive

21 Aug 2017

Dear Sir / Madam, Please find attached the feedback of the French Insurance Federation (FFA) on the Inception Impact Assessment on the REFIT review of the MID. We remain at your disposal for any further information. Yours sincerely, Stéphane de Maupeou Head of the European Office
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Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

27 Jan 2017 · PRIIPs

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

26 Feb 2016 · TTIP

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

17 Jun 2015 · Solvency II

Meeting with Jonathan Hill (Commissioner)

18 Feb 2015 · IORP II, Solvency II, CMU

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

5 Feb 2015 · Introduction meeting