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Insurance Europe

Insurance Europe

Insurance Europe represents European insurance and reinsurance associations, accounting for 95% of European premium income across 39 member bodies.

Lobbying Activity

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

13 Jan 2026 · Simplification, insurance

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

16 Dec 2025 · Annual meeting with Insurance Europe

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Finance Denmark

10 Dec 2025 · Meeting with Danish finance network

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

9 Dec 2025 · Year end stock take with Insurance Europe

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

9 Dec 2025 · Presentation of the Data Union Strategy and the Digital Omnibus Discussion

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

4 Dec 2025 · Policy developments relevant for the insurance sector

Meeting with Dan Jørgensen (Commissioner) and

27 Nov 2025 · Insurability of the housing sector / Long-term investment in housing

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

27 Nov 2025 · Solvency II and the Retail Investment Strategy

Meeting with Konstantina Strouvali (Head of Unit Competition)

27 Nov 2025 · Discussion on the proposed Regulation on Financial Data Access (“FiDA”),in response to Insurance Europe’s letter to DG COMP’s Acting Director-General on 16 October 2025

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

24 Nov 2025 · Supplementary pensions package

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and AMUNDI AM and Swedish Securities Markets Association (Swedish: Föreningen Svensk Värdepappersmarknad)

6 Nov 2025 · Retail investment strategy

Meeting with Wojciech Saryusz-Wolski (Head of Unit (Ad interim) Communications Networks, Content and Technology)

5 Nov 2025 · Exchange of views on the Digital Omnibus, the Digital Operational Resilience Act (DORA), the Cyber Resilience Act (CRA), and the AI Act with an emphasis on simplification and harmonisation of digital legislation.

Meeting with Markus Ferber (Member of the European Parliament, Rapporteur)

29 Oct 2025 · IRRD Implementation

Insurance Europe seeks exemption from Digital Fairness Act provisions

24 Oct 2025
Topic — New EU regulation targeting dark patterns and unfair digital practices
Message — The federation requests that the DFA explicitly recognize insurance-specific regulations as sufficient, exempting the sector from new rules on gamification, personalized pricing, and influencer marketing. They argue the sector is already extensively regulated under IDD, GDPR, and consumer protection directives.123
Why — This would exempt insurers from new restrictions on risk-based pricing and data use.45
Impact — Consumers lose additional protections against manipulative digital practices in insurance products.67
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Meeting with Felix Bloch (Head of Unit Environment)

22 Oct 2025 · Liability/Insurability working group meeting on the Environmental Liability Directive and its evaluation

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

16 Oct 2025 · attached

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

16 Oct 2025 · exchange of views on FIDA, Solvency II and Pensions

Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen)

16 Oct 2025 · Exchange of views on the Vision for Agriculture and Food as well as the aspects of agricultural insurance and re-insurance

Insurance Europe urges Digital Omnibus to reduce compliance burden across AI, cloud, cybersecurity and data rules

14 Oct 2025
Topic — Consultation on simplification of EU digital legislation across multiple regulatory frameworks
Message — Insurance Europe requests elimination of duplicative requirements across digital regulations, clearer guidance on how existing financial services rules meet AI Act obligations, and recognition of contractual necessity as a legal basis under ePrivacy rules. They seek exemption from the Cyber Resilience Act for entities already subject to DORA and streamlined reporting processes that avoid duplication across multiple authorities.1234
Why — This would reduce compliance costs and free resources currently spent navigating overlapping requirements across multiple digital regulations.567
Impact — Consumer and civil society groups lose some independent oversight mechanisms when reporting is streamlined between authorities rather than filed separately.89
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Meeting with Stine Bosse (Member of the European Parliament)

10 Oct 2025 · Pharmaceutical legislation

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and Gesamtverband der Deutschen Versicherungswirtschaft e.V. and MUST Partners

2 Oct 2025 · End-Of-Life Vehicles Regulation

Meeting with Susanne Knoefel (Head of Unit Justice and Consumers)

23 Sept 2025 · Status of the Proposal for an Equal treatment Directive (COM/2008/0426)

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Finanssiala ry - Finance Finland

19 Sept 2025 · EU’s Sustainable Finance Framework, the Savings and Investments Union

Meeting with Fernando Navarrete Rojas (Member of the European Parliament)

18 Sept 2025 · ECON

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

18 Sept 2025 · Discussion on legislative updates and implementation.

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Sept 2025 · Sustainable Finance

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Sept 2025 · Report of Insurance Europe Public Affairs & Communication Committee

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

5 Sept 2025

SII is a comprehensive prudential framework for insurers operating in the EU. The calibrations of key parameters and the new and updated provisions included in the ECs latest consultation will impact the industrys ability to provide products, make investments and to contribute to the EUs wider political objectives including the SIU, Green Deal and enhancing the EU growth and competitiveness. European insurers overall support SII but have long called for targeted changes to SII to address: (1) long term focus, (2) excessive conservatism, (3) artificial volatility, and (4) operational/reporting burdens. The changes to L1 agreed by the co-legislators recognised many of the industrys concerns and introduced several potential improvements to key aspects of SII, including the VA, Extrapolation of RFR, Risk Margin and LTE submodule. The upcoming changes to the SII DR offer a crucial opportunity to deliver on the L1 political agreement and these potential improvements - ensuring that SII remains fit for purpose, supports EU growth and investment, and maintains financial stability and policyholder protection - without introducing new, unintended burdens or hidden conservatisms. Since the launch of the review in 2021, the EC has also placed competitiveness and growth at the heart of the EU policy agenda and committed to simplifying rules for businesses. It is therefore surprising that the EC has not delivered on this potential and aligned the technical proposals with the political ambition. While some draft proposals go in the right direction, overall they fall short of the improvements needed to realise the reviews full potential. In practice, the impact of the review will be incremental rather than transformative. While the industry recognises and welcomes some positive developments, it also brings challenges for companies. These include: Volatility from the miscalibration of the VA risk-correction and the new extrapolation approach. Limitation in supporting long term growth stemming from excessive conservatism in LTEI, risk margin or securitisation. Operational burdens from new liquidity and sustainability plans, added calculation complexity and reporting, going against the EC 25% reduction in operational burden objective. New frictional and uneconomic requirements for internal models and groups. Tight implementation timeline, in Q1 2027, alongside other new developments eg planned IRRD requirements. The changes to the L1 also considerably strengthen supervisory powers, notably in cross-border, macroprudential and group supervision. Priority areas for improvement: Reducing Volatility VA: A calibration based on solid and methodological justification and appropriate data, which preserves the anticyclical nature of the VA. VA: Remove inconsistencies and operational challenges from the CSSR methodology. Extrapolation of RFR: Ensure stability by adding a 2% buffer to the FSP mechanism and set the convergence parameter at 15% (SEK-70%). Growth and competitiveness Risk margin: Set lambda at 92.5% without a floor, aligning the RM with other international frameworks. LTE: Reduce duration criterion from 10 years to 5 to align with L1, review liquidity buffer, amend forced selling tests conditions and expand the list of eligible funds to include UCITS and AIFs to support diversified, long-term portfolios. Securitisation: Further improvements are still required. Group requirements: Remove group-level availability testing of EPIFP and avoid double counting of minimum capital requirements SCR calculation: Adjustments to certain calibrations are needed (eg, expense risk) avoiding undue penalisation of solvency ratios. Reducing Operational burdens Proportionality: Streamline criteria for non-SNCU measures to broaden access. Reporting: Minimise new requirements (eg projections of underwriting performance by LoB and geographical areas in RSR), reduce SFCR (eg sensitivity analysis), limit the RSR to material topics/changes.
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

5 Sept 2025 · Retail investment strategy

Insurance Europe urges focus on prevention to keep risks insurable

4 Sept 2025
Topic — The consultation seeks views on an integrated framework for managing Europe's escalating climate risks.
Message — Prioritize prevention and mitigation to ensure climate-related risks remain commercially insurable. Authorities should mandate transparent risk disclosures for property and offer financial resilience incentives. Resiliency strategies must be tailored to national conditions instead of using EU-wide tools.123
Why — Reducing physical damage helps lower claims costs and maintains the affordability of insurance.45
Impact — National governments and property owners would face increased costs for infrastructure and resilience upgrades.6
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Insurance Europe Urges Simplified Rules to Boost Data-Driven Innovation

18 Jul 2025
Topic — The consultation explores streamlining EU data rules to improve availability and legislative coherence.
Message — The group wants to harmonize overlapping rules like the GDPR and AI Act to remove innovation barriers. They suggest streamlining cyber reporting and clarifying that automated decision-making should be a right, not a prohibition. Finally, they request sector-specific rules for direct access to in-vehicle data.123
Why — Streamlined rules would reduce administrative burdens and allow for more tailored insurance policies.45
Impact — Global tech platforms would be barred from accessing EU consumer financial data to prevent market dominance.6
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Response to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector

17 Jul 2025

Insurance Europe welcomes the European Commissions initiative to strengthen supplementary pensions as part of the broader ambition to build a European Savings and Investments Union. Enhancing retirement income adequacy, fostering long-term investment, and increasing pension participation are crucial objectives, especially in light of demographic shifts and the evolving landscape of national pension systems. The European supplementary pensions landscape is highly diverse, shaped by distinct national contexts, regulatory frameworks, and market structures. Some member states have well-established occupational and/or personal pension systems, which are designed and adapted to local and evolving needs. It is therefore essential that EU-level measures respect this diversity, avoiding prescriptive, one-size-fits-all approaches that risk disrupting functioning national systems or adding unnecessary complexity. Providing all European citizens with clear information about future public and private pension entitlements, in order to raise awareness of the need for savings for instance by promoting pension dashboards or tracking systems, would help many of them make informed decisions about their pensions. Both Member States and the European Commission have a pivotal role to play in making sure that this objective becomes a reality all over the EU. Pension tracking systems and dashboards are valuable tools to enhance transparency, increase awareness, and empower individuals to plan their retirement. However, their design and implementation must remain flexible and adaptable to national realities. The importance of various features within these systems often depends on specific market conditions and pension structures, which differ across member states. Consequently, ranking or prioritising elements uniformly across the EU (as requested in the EC targeted consultation) may not capture this complexity. While caution is needed to ensure that new EU-level initiatives do not interfere with or weaken existing and well-functioning national approaches, the implementation of tracking systems in countries where such systems do not yet exist can provide citizens with clear information about future public and private pension entitlements, helping to raise awareness of the need to save and supporting informed retirement planning. For this reason, Insurance Europe supports the European Commission in offering voluntary guidance and sharing examples of best practices to support member states in exploring or establishing pension tracking systems, where appropriate and in line with national needs. Pension dashboards at European level could be a key tool for the European Commission and national policymakers to monitor pension adequacy and sustainability, helping to reduce pension savings gaps. Such dashboards should include the effects of national measures promoting supplementary pension schemes, which are crucial for reducing these gaps. However, implementing such dashboards should not create extra reporting burdens for insurance companies. Member states could consider implementing automatic enrollment schemes for employees - where appropriate and. (for the full text, please refer to the annex).
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Meeting with Bas Eickhout (Member of the European Parliament)

10 Jul 2025 · Solvency II

Insurance Europe demands inclusion in new EU investment blueprint

8 Jul 2025
Topic — The Commission is developing a blueprint for savings and investment accounts.
Message — Any new initiative must explicitly include insurers as providers to reach diverse consumer profiles. The federation recommends using neutral terms like "investment instrument" and favors flexible, market-driven measures.123
Why — This inclusion ensures a level playing field and allows insurers to capture new retail savings.45
Impact — Banks may lose market share as retail savings are moved from accounts into insurance-based investments.67
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Insurance Europe urges EU to avoid protectionist cloud rules

3 Jul 2025
Topic — The EU aims to triple cloud and AI infrastructure capacity within seven years.
Message — Insurance Europe supports increasing capacity but rejects rules that restrict private sector choices. They want a risk-based approach to sovereign cloud that permits technical and contractual safeguards.12
Why — This allows insurers to continue using high-performing global providers instead of limited local options.3
Impact — Emerging European cloud providers lose the regulatory shield designed to help them compete with US giants.4
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Response to Renewal of the Brazil, Japan and Mexico provisional equivalence decision Art 227 Solvency II

1 Jul 2025

Insurance Europe supports the renewal of provisional equivalence within the Solvency II (SII) regime (Article 227) for Brazil, Japan and Mexico, as per the European Commissions (EC) draft act for feedback. Additionally, Insurance Europe would support the renewal of provisional equivalence for Canada and Australia, where provisional equivalence is due to expire on 31 December 2025. The reasons or criteria that supported the first provisional equivalence designation of these regimes are still valid. In addition, some of the markets included, such as Japan, are in a transition of moving to a SII-like framework. Therefore, in this context, keeping in mind the interests of EU insurers in these markets, continuing provisional equivalence would be appropriate. Renewing provisional equivalence will ensure continuity, stability and a more level playing field for EU insurers operating across borders in these provisionally equivalent markets while promoting economic growth. If provisional equivalence is not renewed, this would create a very significant competitive disadvantage for European insurers in those specific markets, which include some of the largest insurance markets globally. After the extension is confirmed, and as a separate step (in order to avoid any risk of delays in the extension of the existing provisional equivalence), the Commission is asked to clarify the equivalence status of US-associated territories, such as Puerto Rico, and to consider the extension of provisional equivalence to other jurisdictions when they meet the criteria applied to the other countries already covered. These jurisdictions include: Chile China Colombia India Kenya Peru Philippines Singapore South Africa For additional background, please see the Insurance Europe paper from August 2023, at the link below: https://insuranceeurope.eu/publications/2947/insurance-europe-position-on-the-renewal-of-provisional-equivalence-under-solvency-ii/
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Meeting with Yann Germaine (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Jun 2025 · Discussion on Insurance Recovery and Resolution Directive and Insurance Guarantee Schemes

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

23 Jun 2025 · Housing

Insurance Europe Urges Streamlined Cyber Reporting and Voluntary Certification

20 Jun 2025
Topic — The European Commission is consulting on revising the EU Cybersecurity Act to simplify digital regulation.
Message — The organization requests aligning and centralizing cyber reporting under different laws to avoid unnecessary duplication. They also argue that cybersecurity certification should remain voluntary and include more industry feedback.12
Why — Reducing overlapping reporting requirements would lower high compliance costs and administrative burdens for insurers.34
Impact — Sovereignty requirements in certification would harm technology providers by limiting competition and innovation.5
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Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

Insurance Europe welcomes the ECs effort and ambition to build a Savings and Investments Union (SIU). European insurers can play a key role in achieving the SIU goals: they provide protection to citizens and businesses, help people save for old age, are a major long-term investor in the EU economy with 9.5trn, invested in equity, corporate and sovereign bonds. We welcome the ECs efforts to foster more integrated, deeper and efficient EU capital markets by removing regulatory, supervisory and operational barriers hindering key market players and infrastructures. The regulatory environment must underpin European businesses ability to maintain their competitiveness and to contribute to the EUs objectives of innovation and sustainable growth. In this respect, we welcome the ECs focus on regulatory simplification and the clear target to reduce reporting burdens by at least 25%. Excessive and overlapping regulation limit the companies ability to innovate, grow and invest, and its costs are ultimately borne by consumers. In this respect, the Omnibus sustainability simplification package presented by the EC in February 2025 is a positive and crucial first step towards simplifying and improving EU rules. It is vital that the objective to improve competitiveness, to avoid new regulatory burdens and reduce existing ones, is also fully applied to ongoing regulatory developments. For example, key proposals currently in the process of development or finalisation, including the Retail Investment Strategy (RIS), Financial Data Access (FIDA) will add significantly to insurers already high regulatory burden. The regulation and supervision of insurers should be designed to take into account the specific features of insurance. This will ensure that the insurance regulatory regime is focused on the right risks and, ultimately, that consumers and society at large can continue to reap the benefits of a resilient, efficient, innovative, and reliable insurance sector. It is thus important to refrain from simply copying the approaches developed for other sectors. Insurance is captured in a multitude of sector-specific regulations. For this reason, regulation should not be produced in a silo that does not take account existing laws in all areas affected by it. For example, current proportionality frameworks are not sufficiently tailored to the specifics of the insurance sector. This leads to very small insurance undertakings being subject to the same requirements as global players in the real economy an imbalance that must urgently be addressed. When it comes to supervision, the industry supports continued national oversight and efforts by National Supervisory Authorities and EIOPA to use existing tools to continue convergence efforts, while respecting the flexibilities recognised by the regulatory texts as necessary. With respect to convergence tools, Insurance Europe considers that the tools currently at EIOPAs disposal are sufficient and in some cases some potential improvements may be needed to improve their efficiency, eg as regards guidelines and questions and answers. National supervision and local market knowledge is particularly relevant for insurance because the need for and design of many insurance products vary nationally. This is because of the strong links of insurance to national tax, pension, health, judicial, liability and social security systems. The industry has previously acknowledged the need for targeted improvements in cross-border supervision. The Solvency II review will introduce changes to enhance cooperation and coordination between home and host supervisors. The industry supports evaluating the effectiveness of these changes before assessing whether further action is needed. Beyond this, in the context of simplification, the industry welcomes the call of the EC on the ESAs and National Competent Authorities to make full use of currently available tools and implement the simplification agenda.
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Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

5 Jun 2025 · Powering savings and growth: insurers as investors

Insurance Europe demands simplified EU sustainable finance disclosure rules

30 May 2025
Topic — The European Commission is reviewing rules on sustainable finance disclosures to simplify reporting frameworks.
Message — Insurance Europe requests a substantial reduction in the volume and complexity of disclosure requirements. They call for clearer legal definitions of sustainable investments and better alignment with other reporting rules to avoid duplication. The federation also warns against a rigid labelling regime that could exclude diverse insurance products.123
Why — Reducing reporting requirements would lower administrative costs and simplify compliance for smaller insurers.45
Impact — Supervisory bodies might receive less detailed data as the framework prioritizes retail consumer transparency.6
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Meeting with Maria Luís Albuquerque (Commissioner) and

20 May 2025 · Exchange on insurance relevant files

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra)

19 May 2025 · Pillar 2 and the US position on international taxation

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

15 May 2025 · Follow up on Solvency II and ICS

Meeting with Bernardus Zuijdendorp (Head of Unit Taxation and Customs Union)

14 May 2025 · Exchange on global taxation

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

30 Apr 2025 · Insurance Europe (IE) welcomed the SIU Communication and offered to support the dialogue between the Commission (EC) and the insurance sector. The EC shared opportunities for IE participate in targeted consultations and calls for evidences.

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and Association for Financial Markets in Europe and

22 Apr 2025 · FIDA

Meeting with Aurore Lalucq (Member of the European Parliament, Rapporteur)

15 Apr 2025 · Financial Services - SIU

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Svensk Försäkring

1 Apr 2025 · AI in Financial Services

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

1 Apr 2025 · Exchange of views on NBFI topics included in the public consultation performed by the Commission, specifically from insurance sector point of view.

Meeting with Jessika Roswall (Commissioner) and

28 Mar 2025 · Roundtable “Investing in Water Resilience”

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

27 Mar 2025 · F&P Breakfast event

Insurance Europe urges Commission to scrap insurance underwriting KPI

26 Mar 2025
Topic — EU initiative to simplify sustainability reporting and reduce administrative costs for companies.
Message — Insurance Europe recommends removing or suspending the insurance underwriting reporting requirement. They support a 10% materiality filter for investment reporting. They also request simplified criteria for qualifying sustainable activities.123
Why — These changes would reduce administrative burdens and eliminate non-essential reporting obligations.4
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Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

25 Mar 2025 · Discussion on the Financial Information Data Access proposal (FIDA) and the AI framework

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

19 Mar 2025 · Exchange of views on the upcoming revisions to the Solvency II Delegated Regulation, and on various reforms related to the insurance framework

Meeting with Alex Agius Saliba (Member of the European Parliament, Rapporteur)

12 Mar 2025 · Package Travel Directive

Response to Savings and Investments Union

6 Mar 2025

Insurance Europe welcomes the European Commissions effort and ambition to build a Savings and Investments Union (SIU) and will continue to develop proposals and engage in discussions on future solutions to make the SIU a success. European insurers can play a key role in achieving the SIU goals: they provide protection to citizens and businesses, help people save for old age, are a major long-term investor in the EU economy with 9.5trn, invested in equity, corporate and sovereign bonds - and a significant employer. Investing is a fundamental part of insurers business model. By offering savings and retirement products with protection elements such as guarantees and risk covers, through a range of channels, they meet the needs and preferences of consumers. Increasing retail savings through insurance products, combined with targeted improvements to regulations, would make a major contribution to the SIU goals. The following actions can help achieve this: - Ensure that the Retail Investment Strategy (RIS) contributes to the SIU objectives to allow easy access to investment products for retail investors. See recommendations attached. - Improve financial education to increase recognition of the need for savings and insurance (eg pension dashboards or tracking systems) - Introduce/Reinforce tax incentives which are key for motivating people to save for retirement. - Consider sharing good practices in relation to national products and assess the feasibility of a common EU label building on products at a national level. This should aim at generating new savings, while preserving the current diversity of products and distributors. - Before introducing any alternative new product at EU Level, take stock of why the PEPP does not work. To address the barriers to offering PEPPs, fundamental simplification and significant reforms are needed. - Share with member states positive experience with automatic enrolment in pension schemes for employees. The following would help insurers increase investment in assets which are a key for growth and innovation, eg listed equities, venture capital, SME equity and debt, and infrastructure: - Correctly design and calibrate the Solvency II Review Level 2 details. See proposals attached. - Facilitate cross-border investment by reducing the fragmentation in insolvency laws and setting up a process for resolving cross-border disputes. - Increase use of public-private partnerships and have a stronger focus of supernational development banks to crowd-in institutional investors. Partial guarantees can reduce barriers to greater investment and should be recognised under Solvency II (in line with bank regime). - To increase scale and access to venture capital, SME debt and equity, assess national funds and how their use can be expanded to other EU markets or potentially multi-national/EU versions. - For securitisations, introduce more appropriate risk-based capital requirements in Solvency II and reduce due diligence requirements. - Remove IFRS disincentives for equity and venture capital investment, due to IFRS not allowing certain capital gains to be reflected in profit (equity recycling issue). See proposals attached. The regulatory environment must underpin businesses ability to maintain their competitiveness and to contribute to the EUs objectives of innovation and sustainable growth. - We welcome the ECs focus on regulatory simplification and improving competitiveness, avoiding new regulatory burdens and reducing existing ones. It is vital that it is applied in regard to ongoing regulatory developments (eg Solvency II, RIS and FIDA). - When it comes to supervision, we support continued national oversight and efforts by National Supervisory Authorities and EIOPA to use existing tools to continue convergence efforts, while respecting flexibilities allowed in regulatory texts.
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Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Association for Financial Markets in Europe and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque) and Associação Portuguesa de Seguradores

20 Feb 2025 · Discussion on developments regarding insurance market.

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

19 Feb 2025 · discussions on Green Claims Directive

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur)

6 Feb 2025 · FIDA

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and Gesamtverband der Deutschen Versicherungswirtschaft e.V. and

6 Feb 2025 · End of life vehicles

Insurance Europe urges EU to cut insurance regulatory burden

31 Jan 2025
Topic — The Commission is consulting on removing barriers to improve Single Market global competitiveness.
Message — The organization calls for a significant reduction in the regulatory and reporting burden. They request sector-specific rules and sufficient implementation time.123
Why — Reducing compliance costs would allow the sector to increase investment and provide more insurance cover.4
Impact — Transparency groups may lose access to granular data if sustainability reporting requirements are streamlined.5
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Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen) and

14 Jan 2025 · The role of the automotive aftermarket in the EU Industrial Action Plan for the automotive sector

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

13 Jan 2025 · EFRAG’s mandate, Omnibus proposal, SFDR review and other planned initiatives

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas) and European Association Automotive Suppliers and

10 Jan 2025 · Introductory meeting

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS and

9 Jan 2025 · EU-UK Financial Regulatory Forum

Meeting with Valvanera Ulargui Aparicio (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and European Association Automotive Suppliers and

16 Dec 2024 · Exchange with the Independent Service Providers (ISPs) on the upcoming Commission Initiatives that will support the whole sector competitiveness, including the Competitiveness Compass, the Clean Industry Deal and the Automotive Industry Plan

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament) and European Banking Federation and

3 Dec 2024 · Savings and Investments Union

Meeting with Gilles Boyer (Member of the European Parliament) and Association for Financial Markets in Europe and

3 Dec 2024 · CMU

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

28 Oct 2024 · Right to be forgotten

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and European Cancer Organisation

1 Oct 2024 · right to be forgotten

Meeting with Anouk Van Brug (Member of the European Parliament)

26 Sept 2024 · Meeting

Insurance Europe urges repeal of EU tax avoidance rules

11 Sept 2024
Topic — The European Commission is evaluating its directive targeting common tax avoidance practices.
Message — Insurance Europe recommends repealing the directive and related reporting standards. They argue that new global tax rules have made these measures redundant and costly. They also request simplification of rules to reduce burdens on multinational businesses.123
Why — This would decrease significant technical and administrative costs for the insurance sector.45
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Response to Report on the first review of the EU-US Data Privacy Framework

6 Sept 2024

Insurance Europe welcomes the opportunity to provide feedback to the European Commission (EC) in view of its EU-US Data Privacy Framework (DPF) review report. Please find our comments in attachment.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

10 Jul 2024 · Right to be forgotten

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Association Automotive Suppliers and

4 Jun 2024 · Discussion on preparation of delegated act on conditions to access data for repair and maintenance activities

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

24 May 2024 · Right to be forgotten

Meeting with Markus Ferber (Member of the European Parliament) and Deutsche Bank AG

20 Mar 2024 · Ongoing financial services legislation

Insurance Europe warns against mandatory insurance for travel organisers

12 Mar 2024
Topic — A review of EU rules ensuring robust consumer protection for package travellers.
Message — Insurance Europe opposes mandatory insurance requirements and calls for the removal of retailer insurance provisions. They urge strict limits on pre-payments and want organisers to have clear redress rights from third parties.123
Why — Avoiding mandatory coverage protects insurers from being forced to underwrite uninsurable systemic risks.4
Impact — Travellers would suffer from higher holiday prices if mandatory insurance requirements are imposed.5
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Response to Prolongation of the US provisional equivalence decision Art 227 Solvency II

4 Mar 2024

Insurance Europe welcomes the publication of the ECs draft decision on the prolongation of US provisional equivalence under Solvency II. The industry supports the renewal of provisional equivalence within the Solvency II regime (Dir Art 227) for the US. The reasons or criteria that supported the first provisional equivalence designation of the US regime are still valid and nothing should prevent the renewal. After the extension is confirmed, and as a separate step (in order to avoid any risk of delays in the extension of the existing provisional equivalence), the Commission is asked to clarify the equivalence of Puerto Rico, considering both its status as U.S. territory and the fact that its NSA is a member the National Association of Insurance Commissioners (NAIC) following the exactly the same prudential regime as the rest of the U.S. states. Insurance Europe would like to stress that renewing provisional equivalence will ensure continuity, stability and a more level playing field for EU insurers while promoting economic growth, and the draft equivalence decision is a welcome step in that direction. Insurance Europe considers that the same reasoning should also apply to the renewal of equivalence decisions for Canada, Japan, Australia, Brazil and Mexico. Please find the attached document for the full response.
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Meeting with Markus Ferber (Member of the European Parliament)

14 Feb 2024 · Retail investment Strategy

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

14 Feb 2024 · Retail investment Strategy

Insurance Europe urges practical GDPR interpretation to support digital innovation

7 Feb 2024
Topic — The European Commission is evaluating the application of the General Data Protection Regulation.
Message — Insurance Europe requests that the Commission address obstacles to innovation and simplify international data transfers. They call for a more risk-based approach from regulators and clarification on the legal basis for processing health data.123
Why — These changes would reduce administrative burdens and provide legal certainty for adopting new technologies.45
Impact — Individual data subjects may lose the right to access personal data stored in backup systems.67
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

Please find Insurance Europe's feedback to the BEFIT proposal in the document attached.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

24 Jan 2024 · Fida

Meeting with Tove Ernst (Cabinet of Commissioner Stella Kyriakides) and European Banking Federation and European Mortgage Federation - European Covered Bond Council

10 Jan 2024 · Europe’s Beating Cancer Plan; quality of life”

Response to Advanced alternative dispute resolution for consumers

4 Jan 2024

Insurance Europe welcomes the opportunity to respond to the European Commissions consultation on the review of the current ADR directive. Insurance Europe supports the reviews objective which is to adapt this framework to the digital market and its recent evolutions while improving cross-border ADR dispute resolution. Nonetheless, Insurance Europe is of the view that: - extending the scope of the ADR procedures to non-contractual consumer rights (Article 2) will result in unintended consequences and will not be feasible. - while the ADR entities are mainly financed by European businesses, allowing third-country traders to take part in ADR procedures, risks having free riders benefitting from ADR resources while damaging the reputation of a whole sector. Please find Insurance Europe's full response in the attached file.
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

1 Jan 2024

Please find (below and attached) Insurance Europe's feedback on the European Commission's proposal for a Transfer Pricing directive. Insurance Europe shares the goals of the proposed Transfer Pricing (TP) directive. At the same time, Insurance Europe highlights the importance that EU legislation does not deviate -now or in the future- from the OECD's transfer pricing guidelines, as this would create additional challenges for groups that operate both inside and outside the EU. The purpose of the proposed directive is to codify the OECD's transfer pricing guidelines in EU law and to thus create a unified interpretation of the market conditions principle. The OECD's transfer pricing guidelines have a significant impact in the field of transfer pricing; however, the guidelines are currently implemented in the laws of member states to varying degrees. The OECD's transfer pricing guidelines are less binding than EU law. The implementation of the proposed TP Directive will be based on the consensus among member states in the Council of the EU. However, this might cause problems, separating the future EU rules from the principles agreed at OECD might cause problems. It should also be taken into account that the translation of the OECD instructions into the EU Directive, and finally their translation into the national legislation and implementation at national level, is a long and time-consuming process.
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Response to Reporting reduction package - amendments to the ESA, ESRB and InvestEU Regulations

22 Dec 2023

While the changes to Regulation (EU) No. 1094/2010 (establishing the European Insurance and Occupational Pensions Authority (EIOPA)) are important for the insurance industry and the initiative to reduce the reporting burden is very much welcomed, the following observations are made: Art 29 and 30 - The proposed amendments to Art. 29 and 30 of the EIOPA Regulation will not provide relief in the short term as they contain a mandate to identify and propose the elimination of redundant and obsolete reporting requirements in the application of regulatory and implementing technical standards, guidelines, recommendations, etc. Furthermore, the amendments include an assessment of the effectiveness and convergence of national reporting requirements through peer reviews. Despite these provisions, there is no specified timeframe, and against this background it is recommended to initiate the process provided for in Art. 29, immediately after the amending Regulation comes into force. This process should be linked to a specific reporting obligation to the European Commission (EC), Council of the European Union, and European Parliament (EP), within, for example, one year. - Furthermore, the industry highlights that the focus of convergence should be on reducing the reporting burden for companies. It should not result in additional reporting requirements or a tendency towards increased conservatism. Art 35a (new) - Art. 35a (new) could have an immediate effect as it directly obliges EIOPA and the National Supervisory Authorities (NSA) concerned to exchange information if there is a legal basis for the request for information from the requesting authority. The industry notes that the primary goal of data sharing should be the reduction of the reporting burden for companies. - Concerning paragraph 7 - the industry does not support granting data access to competitors, researchers etc. The content of the paragraph goes beyond the purpose of this proposal and lacks clarity in legal terms. Furthermore, the drafting is too vague, particularly with regard to the meaning of ''entities with a legitimate interest in such information'' implies and the potential impact. - Anonymisation of data is not sufficient as a safeguard particularly in the case of privacy and competition. Please find attached the Insurance Europe comments.
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Meeting with Jessica Polfjärd (Member of the European Parliament)

5 Dec 2023 · RIS Discussion

Insurance Europe Urges EU to Slash Excessive Reporting Burdens

29 Nov 2023
Topic — The European Commission initiative seeks to reduce corporate reporting requirements by 25%.
Message — Insurance Europe requests the removal of redundant quarterly reporting and the elimination of overlaps between pieces of legislation. They demand that implementation periods for new rules should be 18 months by default to manage the compliance burden.123
Why — Streamlining these requirements would lower compliance costs and allow for more business innovation.4
Impact — Customers and consumers suffer from higher costs and an overwhelming amount of information.567
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Meeting with Ralf Seekatz (Member of the European Parliament, Shadow rapporteur)

28 Nov 2023 · Kleinanlegerstrategie

Insurance Europe seeks narrower scope for EU financial data rules

1 Nov 2023
Topic — New EU framework for sharing financial data beyond payment services among third-party providers.
Message — The federation requests a step-by-step implementation focusing only on retail customers and demonstrated use cases. It seeks explicit exclusions for sensitive health data and proprietary trade secrets to protect competitive innovation. They also propose a two-stage implementation timeline to allow for technical development.123
Why — A narrower scope and phased timeline would reduce compliance costs and protect internal models.45
Impact — Tech gatekeepers and commercial clients would be excluded from accessing valuable insurance data sets.67
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Meeting with Rasmus Andresen (Member of the European Parliament, Shadow rapporteur) and European Banking Federation and

12 Oct 2023 · ESG

Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

4 Oct 2023 · FIDA

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

27 Sept 2023 · RIS/roundtable

Insurance Europe urges regulation of raw ESG data products

31 Aug 2023
Topic — EU legislative initiative to improve transparency and reliability of ESG ratings.
Message — The federation requests that raw ESG data and estimates be included within the regulatory scope. They also call for closing loopholes involving subsidiaries and ensuring users have full access to rating methodologies.12
Why — This would reduce insurers' exposure to greenwashing risks and improve the reliability of investment data.3
Impact — Dominant data providers might lose revenue as fees must reflect actual costs.4
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Insurance Europe warns EU investment rules could limit advice

28 Aug 2023
Topic — A legislative package seeking to increase retail investor participation in capital markets.
Message — The group demands removing proposed bans on commissions for financial product sales. They also request revising value-for-money benchmarks and streamlining complex investor tests.12
Why — This allows insurers to maintain existing distribution models and avoid high compliance costs.3
Impact — Small investors lose access to professional advice due to unaffordable upfront service fees.4
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Insurance Europe demands consistent EU green claim regulations

20 Jul 2023
Topic — EU initiative requiring companies to verify environmental performance claims using standard footprint methods.
Message — The federation calls for the directive to be aligned with existing financial regulations. They request uniform criteria to prevent inconsistent implementation across different member states.12
Why — Alignment with existing laws would reduce compliance costs and prevent redundant administrative burdens.34
Impact — Environmental groups would face restricted access to justice and limited influence over authorities.56
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Response to Cyber Solidarity Act

20 Jul 2023

Insurance Europe fully supports the European Commission's goal to strengthen solidarity and enhance coordinated EU cyber threat detection and awareness, as well as to support Member States' (MS) preparedness and response capabilities in relation to significant or large-scale cybersecurity incidents. Europes insurers notably welcome the recognition of insurance as having a role to play in enhancing cyber resilience.
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

Insurance Europe seeks better alignment for sustainability reporting rules

7 Jul 2023
Topic — The consultation concerns delegated acts specifying European standards for corporate sustainability reporting.
Message — Insurers demand better alignment between reporting and financial disclosure rules. They request phased value chain reporting and interoperability with global standards.123
Why — This would prevent duplicative reporting and reduce the burden on international groups.45
Impact — Stakeholders lose visibility into companies’ social and environmental impacts across supply chains.6
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Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

6 Jul 2023 · Retail Investment Strategy (ECON)

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

11 May 2023 · Retail Investment Strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

11 May 2023 · Retail Investment Strategy

Insurance Europe seeks one-year delay for green reporting

3 May 2023
Topic — The initiative defines a classification system for environmentally sustainable economic activities.
Message — Insurers request a one-year delay for reporting on green investment eligibility. They also urge the Commission to simplify templates and remove redundant reporting requirements.12
Why — The delay ensures insurers have necessary data from the companies they fund.3
Impact — Investors lose transparency because the 2025 reporting year would be left uncovered.4
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Meeting with Pascal Durand (Member of the European Parliament)

28 Apr 2023 · EFRAG (APA only)

Meeting with Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

21 Apr 2023 · Retail Investment Strategy

Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · Exchange of views on the Product Liability Directive/ Produkthaftungsrichtlinie (PLD) - Staff Level

Meeting with Pascal Arimont (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

12 Apr 2023 · Revision of the Product Liability Directive

Response to VAT in the Digital Age

3 Apr 2023

See the attached file for Insurance Europe's response.
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur) and COMPAGNIE NATIONALE DES COMMISSAIRES AUX COMPTES

29 Mar 2023 · Solvabilité II

Meeting with Pascal Canfin (Member of the European Parliament)

28 Mar 2023 · Green finance

Meeting with Pascal Durand (Member of the European Parliament)

17 Mar 2023 · ESRS (APA only)

Meeting with Pascal Arimont (Member of the European Parliament, Rapporteur) and Application Developers Alliance and Association Mieux Prescrire

14 Mar 2023 · Revision of the Product Liability Directive

Response to Transitional measures for smart tachograph 2 regarding its use of OSNMA

8 Mar 2023

The feasibility of providing vehicles with a G2V1, which are registered after August 21, 2023, with a G2V2 tachograph is not possible. The suppliers of the G2V2 tachograph will probably supply the tachograph to the after market from July 1, 2023. This means that the conversion action must be completed within seven weeks. Knowing that this coincides with the holiday period, this is not possible with the capacity of the tachograph calibrator. In addition to this short period, it is necessary to train several technicians to replace and calibrate tachographs. The training must be initiated by the suppliers of the tachographs. To meet this demand nationwide, training capacity must be scaled up. These arguments indicate that the adtum of August 21 is not feasible.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Alfred Sant (Member of the European Parliament)

1 Mar 2023 · Retail Investors Strategy

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

23 Feb 2023 · Solvency II review; retail investment strategy

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

17 Feb 2023 · Solvency II review, Retail Investment Strategy

Insurance Europe urges EU action on mental health awareness

15 Feb 2023
Topic — The Commission is developing a multidimensional policy framework to address deteriorating mental health.
Message — The federation recommends using EU influence to raise awareness and encourage early medical treatment. They advocate for better coordination between specialists and general practitioners to improve patient care outcomes. The group also emphasizes the need for initiatives that reduce stigma and social taboos.123
Why — Better prevention reduces overall medical expenses, ensuring that mental health risks remain commercially insurable.4
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · In-vehicle data

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

6 Feb 2023 · Access to in-vehicle data

Meeting with Simon Genevaz (Cabinet of Executive Vice-President Margrethe Vestager)

6 Feb 2023 · Access to in-vehicle data

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

1 Feb 2023 · Retail investment strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

1 Feb 2023 · Retail Investment Strategy

Meeting with Pascal Durand (Member of the European Parliament, Rapporteur for opinion)

1 Feb 2023 · ESAP EFRAG CSDDD (APA only)

Response to Review of the Designs Directive

30 Jan 2023

Please find attached Insurance Europe's contribution to this call for feedback.
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Insurance Europe Urges Optional Application of New Tax Framework

26 Jan 2023
Topic — This consultation seeks views on a common European corporate tax framework.
Message — Insurance Europe advocates for an optional approach to protect limited cross-border operations. They request impact assessments and rules tailored to the insurance business model.123
Why — Optionality would allow insurers to avoid the high costs of changing accounting systems.45
Impact — Taxpayers face legal uncertainty if new rules lack the depth of national systems.67
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Insurance Europe demands sector exemption from new cybersecurity rules

23 Jan 2023
Topic — The consultation establishes common cybersecurity standards for digital products across the EU.
Message — The insurance sector should not be included in the scope of requirements. Existing rules like DORA should remain the single framework applicable to the industry.12
Why — Stronger security standards for digital products make it easier for insurers to cover risks.3
Impact — European manufacturers risk losing their competitive edge against companies based outside the EU.4
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

19 Jan 2023 · Insurance Europe wanted to discuss the European Insurance sector and their main concerns in relation to the following files: 1) Retail investment Strategy 2) Solvency II

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Lufthansa Group and European Alliance for Research Excellence

17 Jan 2023 · Data Act

Meeting with Markus Ferber (Member of the European Parliament, Rapporteur)

12 Jan 2023 · Insurance Regulation: Solvency II

Meeting with Mairead McGuinness (Commissioner) and

10 Jan 2023 · Solvency II and retail investment strategy.

Insurance Europe Warns Revised Liability Rules Threaten Insurance Availability

9 Dec 2022
Topic — The European Commission is updating liability rules for digital and circular products.
Message — Insurance Europe calls for the reconsideration of rules regarding psychological harm and cyber risks to ensure risks remain priceable. They advocate for maintaining legal certainty to prevent an unmanageable increase in litigation.12
Why — Restricting the liability scope helps insurers avoid unpredictable costs and ensures they can continue offering coverage.34
Impact — Consumers face higher prices for goods as manufacturers pass on the increased costs of litigation and insurance.56
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

1 Dec 2022 · Organisation of call between Commissioner McGuinness and Insurance Europe

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

17 Nov 2022 · retail investment strategy; Solvency II

Response to Strengthening social dialogue

20 Oct 2022

Insurance Europe believes that sectoral social dialogue is an important instrument contributing towards the EU’s objectives to achieve sustainable economic development and resilience in Europe. With their specific knowledge of each sector, sectoral social partners are closer to the needs of companies and employees and they are best placed to discuss and, where appropriate, develop solutions according to national law and practice. Sectoral social partners are also in a better position to deliver a concrete picture of each sector and can provide specific data that can be used in the design of policy proposals. The Insurance Sectoral Social Dialogue Committee (ISSDC) — of which Insurance Europe is an active member — has enabled social partners to address several issues of key relevance to employers and employees in the insurance sector, such as digitalisation, artificial intelligence and COVID-19. European sectoral social dialogue will need to continue to play a strong role in the future. To facilitate this, Insurance Europe invites the Commission to: - Improve the visibility and accessibility of sectoral social dialogue deliverables. The outcomes of European social dialogue (such as process-oriented texts, joint opinions and tools) are only meaningful if they can be discussed, translated and used by national social partners. The European Commission should facilitate access to translation resources and improve the visibility of the outcomes of the sectoral social dialogue committees on their dedicated websites. The Commission and national authorities should substantially increase the visibility they give to joint outcomes of sectoral social dialogue, within and outside their institutions, and in the context of legislative and non-legislative processes. - Ensure that sectoral social dialogue has appropriate resources. Budgets for sectoral social dialogue are being reduced and the administrative work to organise European social dialogue activities has been increasingly moved from the European Commission to the social partners. The Commission should review its approach to allow the social partners to focus on their core role in social dialogue. - Facilitate coordination between sectoral social dialogue committees. Regular exchanges between sectors on common issues could benefit all social partners and help increase the weight given to the outcomes of social dialogue committees. The European Commission should further facilitate such cooperation while ensuring the role and the autonomy of the individual sectoral social dialogues. - Raise the profile of social dialogue within the EU and increase awareness of its importance. In this regard, Insurance Europe agrees with the suggestion by Andrea Nahles, special advisor to Commissioner Schmit, that sectoral social partners should have greater involvement in the European Semester. - Improve consultation with social partners on Commission initiatives. Insurance Europe believes that sectoral social partners should be involved in the EU’s policymaking process at the earliest possible stage. While consultation with social partners works relatively well in employment and social policy, there is room for improvement in other policy areas. Insurance Europe welcomes the proposal by Andrea Nahles to appoint a social dialogue coordinator in each directorate-general. This would ensure a more consistent approach to consultation with social partners across the Commission. - Support capacity-building to benefit national social partners. The capacities of national social partners vary substantially across Europe. In recent years, the European social partners have urged the EU to step up its financial support for capacity-building and have called on national governments to make better use of the available funding.
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

22 Sept 2022 · Solvabilité II - IRRD

Response to Review of EU rules on payment services

2 Aug 2022

Insurance Europe welcomes the stated intentions of the European Commission to carry out a comprehensive review of the application and impact of the payment services framework (PSD2), including an overall assessment of whether it is still fit for purpose and what challenges have arisen in its application. Insurance Europe believes that there needs to be an appropriate focus on evaluating, assessing and analysing the impact, costs and benefits of PSD2. It is important to ensure that lessons are learned and that policymakers quantify and qualify the increased costs of such a framework compared to the actual benefits and risks faced by the financial sector. An in-depth analysis is required to determine whether or not the PSD2 framework has delivered on its initial goals and successfully achieved its objectives, ie, improved services for consumers and increased competition in the market. This is particularly important in light of the European Commission’s on-going considerations regarding a possible open finance framework. It is crucial that any new initiative in the area of data sharing is not based on a copy across of the PSD2 framework. PSD2 was designed to increase innovation and competition in banking and payment services. Insurance, for example, is different in many ways from traditional banking and payment services. As the Commission noted in its digital finance strategy consultation, the PSD2 framework is limited to payment data held by payment services providers and does not cover other types of data relevant to financial services and held by other firms within and outside the financial sector. In contrast, insurance data consists of a complex mixture of very diverse types of data which are very heterogenous in nature. PSD2 data is less sensitive than data that has its origin in the insurance sector. The focus should therefore be on learning the lessons of what has or has not worked under PSD2, as part of a thorough review of the existing framework. For example, it has proven difficult under the PSD2 framework to harmonise standards for information exchange and application programming interfaces (APIs). The process of approval of APIs by national authorities has been burdensome, challenging and in some cases problematic, as the same APIs have been approved in one country and not in another. Appropriate consideration therefore needs to be given to the standardisation of APIs. It will also be important to use this review to reflect on how to ensure a fair allocation of costs related to developing any new, cross-sectoral data-sharing infrastructure among the different players to ensure a balanced approach to the funding and development of any new infrastructure.
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Response to Open finance framework

2 Aug 2022

Open finance, if designed with the right framework, has the potential to positively impact both consumers and insurers. However, it is important to get the framework right, so that the potential can truly be achieved. This raises important considerations in relation to consent management, the scope of the data sharing and ensuring a level playing field among market participants. In addition to our response to the targeted consultation on open finance, please find attached Insurance Europe’s views on a possible open finance framework.
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Insurance Europe urges health data access for premium setting

28 Jul 2022
Topic — A European Commission proposal to facilitate the cross-border exchange of health data.
Message — Insurance Europe requests removing the prohibition on using electronic health data for premium setting. They seek clearer definitions to ensure private insurers are not burdened with data-sharing obligations.12
Why — Accurate data access allows insurers to calculate risks precisely and maintain competitive pricing.3
Impact — Policyholders might face more expensive insurance due to pricing uncertainty from data gaps.4
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Meeting with Pascal Durand (Member of the European Parliament, Rapporteur for opinion)

19 Jul 2022 · ESAP (APA only)

Response to Distance Marketing of Consumer Financial Services - Review of EU rules

8 Jul 2022

Please see Insurance Europe feedback in attachment.
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Meeting with Alfred Sant (Member of the European Parliament)

5 Jul 2022 · Solvency II

Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur for opinion) and Banco Santander, S.A. and

28 Jun 2022 · Joint exchange of views on the Data Act

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

27 Jun 2022 · Solvency II/IRRD

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness)

23 Jun 2022 · Retail Investment Strategy

Insurance Europe urges free access to high-value public datasets

21 Jun 2022
Topic — The European Commission is seeking feedback on mandatory publication standards for high-value public datasets.
Message — The group supports establishing a list of datasets available free via digital tools. They also request including company ownership and road traffic safety data.12
Why — Better data allows insurance companies to create more sophisticated and competitive risk models.3
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Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Data Act ; in-vehicle data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Tyre & Rubber Manufacturers' Association and

10 Jun 2022 · Prep meeting for meeting with Commissioner Breton on 16/6

European insurers urge caution on retail investment law changes

31 May 2022
Topic — This consultation explores initiatives to enhance retail investor confidence and participation in capital markets.
Message — Insurance Europe requests a full evaluation of existing rules before any new legislation. They emphasize the need for simpler disclosures and protecting current distribution systems.12
Why — Limiting new regulations avoids additional operational costs and protects their established distribution systems.3
Impact — Retail customers might face restricted product choices and reduced access to professional financial advice.4
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Insurance Europe seeks major revisions to EU sustainability law

23 May 2022
Topic — EU proposal mandating companies to identify and mitigate environmental and human rights risks.
Message — The federation requests that sector-specific rules prevail and requirements apply only at the group level. They also advocate for excluding civil liability and limiting the scope to direct business partners.123
Why — Higher employee thresholds and reduced liability would lower legal costs and administrative burdens.45
Impact — Victims of environmental or human rights abuses would face significant legal hurdles for compensation.67
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Insurance Europe urges specific automotive rules and trade secret protections

13 May 2022
Topic — An EU initiative setting rules for sharing data generated by connected devices and digital services.
Message — The group demands dedicated laws for vehicle data and exemptions for trade secrets to protect innovation. They also want protections against unfair contracts extended beyond small businesses to all companies.123
Why — Better access allows insurers to refine risk models and reduces reliance on dominant cloud providers.45
Impact — Car manufacturers and cloud giants lose the power to unilaterally dictate data access and pricing.6
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

2 May 2022 · Retail Investment strategy, Solvency II review

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur)

27 Apr 2022 · Solvency II review & IRRD

Meeting with Aurore Lalucq (Member of the European Parliament, Shadow rapporteur)

21 Apr 2022 · IRRD

Response to Minimum level of taxation for large multinational groups

5 Apr 2022

Insurance Europe welcomes the opportunity to provide feedback through the “Have your say” tool and wishes to raise some critical concerns and highlight the need for clarifications of some key elements of the EC’s work on the proposal for a Directive on ensuring a global minimum level of taxation for multinational groups in the EU, and for the implementation of the OECD Model Rules. The industry has several concerns: the first relates to the interaction of Pillar 2 with certain domestic tax treatments, which risk being overridden by the global rules. Insurers are also concerned about the definition of insurance investment funds, which does not reflect the reality of the insurance business, and would trigger a top up tax due to the limited scope of the elections provided by Articles 40 and 41. A fundamental policy concept of Pillar Two is to examine Effective Tax Rate (ETR) over a period of time to neutralise the consequences stemming from the application of the annual accounting concept. The requirement that deferred tax balances be recast at the minimum rate undermines the ability of the rules to achieve the policy objective of smoothing the ETR and does not appear to be justified. Regarding the calculation of the ETR, the introduction of a carry forward or averaging instrument would be appropriate. Clarity is also required regarding the treatment of Restricted Tier 1 (RT 1) Capital, which insurers can issue under Solvency II regulations. The treatment of RT 1 capital is identical to Additional Tier 1 Capital in the banking sector. The rules should therefore be applicable to the insurance sector, otherwise insurers would be negatively impacted by the inefficient access to capital markets. Insurers also have further concerns related to the consolidation scope and the substance-based income exclusion and ask the EC to consider the administrative burden that these proposals may lead to, as well as the eventual competitive disadvantage for the industry. Insurance Europe suggests adopting a more risk-based approach in the definition of group and constituent entity by excluding immaterial entities in the GloBE scope which may result in a significant reduction of compliance costs for the Multinational Entity group, while continuing to ensure the effectiveness of the GloBE rules. Due to the considerable compliance effort for companies both at the time of introduction of the new rules and afterwards, further simplifications are necessary. In that sense, insurers welcome the development of elective simplification measures and safe-harbours, and call for the implementation of a sunset clause whereby all or a set of provisions in the Directive cease to have effect after a certain period (eg two years). This would allow fine-tuning and further simplification adjustments of the Pillar 2 rules. The points raised above are discussed in detail in the attachment. There are several other aspects of the proposed rules that remain to be clarified: for instance the implications for the recognition of pre-regime losses or the treatment of joint ventures under the new rules. They should be properly addressed either via implementation guidelines or via a clarification of the proposal for a Directive.
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Response to Proposal for a Council Recommendation on long-term care

29 Mar 2022

While life expectancy appears to be stalling in many European countries, the average population age continues to increase, and will do so for years to come. It is therefore vital to ensure that, in the future, an increasing number of people have access to affordable healthcare throughout their old age. Against this background, Insurance Europe welcomes the European Commission’s call for evidence and looks forward to the upcoming discussions. There are several ways to ensure accessibility and affordability of long-term care across Europe, and these should reflect the various approaches implemented by individual member states. Despite this diversity, there is a broad consensus in most countries that the private insurance industry has a major role to play to reconcile adequate and affordable healthcare and long-term care coverage with fiscal and financial sustainability, and that it could play an even greater one in the future. European insurers have extensive experience regarding the provision of health and long-term care services, albeit linked to the organisation of national health systems. - Private health insurers typically fulfil a supplementary, complementary or substitutional role; or, in some cases, a combination of these three types of roles (depending on the national set-up). - Private insurers often allow policyholders to benefit from faster access to treatment and a wider choice of healthcare providers. - Pooling and smoothing of risks over long periods of time are the essence of private insurance. Insurers can offer relatively stable lifetime premiums to customers, using “ageing reserves”. Indeed, as claims costs tend to rise with age, early access to private health insurance allows policyholders to build up their “reserve” and therefore achieve affordable insurance in later life. Insurers remain committed to continuing to provide these services and to supporting governments where possible. In order to do so, it will be vital for member states to ensure that the right conditions are in place to enable insurers to play their role. - Tax incentives could, for instance, play a role in ensuring that insurance products remain affordable and attractive. - Insurers are also keen to explore with authorities the possibility to expand their range of activities. This could include, for instance, acting as gateways to services — especially services that encourage prevention, awareness and adaptation, areas in which insurers have experience and which are vital to keep healthcare costs affordable. As mentioned earlier, healthcare and social affairs are still predominantly regulated by individual member states. Nonetheless, the insurance industry takes the view that the EU has a role to play. In particular, the Commission could explore ways to support member states in making insurance cover more accessible and affordable: - It is vital for all member states to develop approaches that will likely decrease the pressure on health systems, and the Commission could play a role in promoting such approaches. Of particular importance is prevention, notably by promoting healthy lifestyles and making appropriate use of digital solutions. - Public private partnerships (PPPs) and, in particular, the exchange of information and good practices between stakeholders could contribute to addressing long-term care challenges. The EU could support member states by promoting the value of and supporting the set-up of such PPPs. - Another element to consider is the importance of clear information to citizens. Citizens should have clear information about what the public sector covers them for in terms of health and social services, so that they can take responsibility for any gaps in their coverage.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

25 Mar 2022

The European insurance industry welcomes the European Commission’s proposal establishing a European Single Access Point (ESAP). It will allow insurers, Europe’s largest institutional investors, to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format, steer their investment portfolios more effectively towards sustainability objectives and comply with their disclosure requirements. The insurance industry supports the fact that:  ESMA must establish the ESAP by 31 December 2024.  The ESAP does not create new reporting requirements and includes ESG data relating to the Corporate Sustainability Reporting Directive (CSRD), Sustainable Finance Disclosures Regulation (SFDR) and Taxonomy Regulation (TR).  The proposal respects the “file only once principle” to avoid redundant reporting channels. However, Insurance Europe stresses the following:  Free or low fee to access ESAP. Access for users such as insurers who need the ESAP data to make sustainable investment decisions and comply with regulatory reporting requirements should be free. If deemed necessary for the rapid development of a well-functioning, reliable and user-friendly platform, insurers could support a small fee to access and use the ESAP but it is important to distinguish between different categories of ESAP users. The fee should be significantly lower than for data providers using data as part of their business model. It might be relevant to allow differentiated access to stakeholders from outside the EU.  The EC should develop an implementation roadmap specifying a phased approach with ESG data needed under the CSRD, SFDR and TR available in phase 1. Financial, prudential and other types of information could be incorporated in later phases to avoid delay in establishing the ESAP. Alignment of the entry into force of new disclosure obligations with the timing of data availability through the ESAP is crucial.  Strong governance, stakeholder and expert input is key to the successful development of ESAP. Insurers support the establishment of an advisory steering board, composed of users, preparers, national and European competent authorities, to advise ESMA on the set-up and running of the ESAP.  Voluntary data submission from non-EU companies should be possible so that EU companies with investments outside the EU can fulfil their reporting obligations. Further clarity is needed (including on the relevant equivalence mechanism) to encourage voluntary reporting.  Data format and ITS: technical specifications on data formatting should be made rapidly available so that entities can carry out the relevant IT developments and be ready to comply with the ESAP requirements.  Inclusion of certain product information in the scope is premature.  An assessment should be made, when the review of the packaged retail and insurance-based investment products (PRIIPs) framework is finalised, to determine whether the revised PRIIPs key information document (KID) is fit for purpose and whether the information should be included in the ESAP. As it stands, the current PRIIPs KID does not fairly reflect the specific features of insurance-based investment products. It applies to products that have no investment objectives and for which the KID is not suited.  There is currently no practical experience with the pan-European personal pension product (PEPP) KID and therefore no confirmation that it would work as intended and deliver information that is correct and meaningful.  The ESAP should not duplicate manufacturers’ compliance efforts and delay the marketing of new products. Overlap with other initiatives (EIOPA’s PEPP register for example) should be avoided.  Art. 7 of the TR should be excluded from the ESAP’s scope as it requires adding a statement to pre-contractual and periodic documents of financial products not subject to Art. 8-9 of the SFDR. It is not a stand-alone document, there is no obligation to publish this online
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Response to Long Term Investment Funds – Review of EU rules

21 Mar 2022

The European insurance industry welcomes the European Commission’s proposal to review the European Long-Term Investment Funds (ELTIF) Regulation. As the insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, improvements made to the ELTIF framework to make it more appealing to institutional investors are supported. In particular, the industry supports the following:  The proposed refinements to the framework to reduce barriers to the issuance of ELTIFs will improve its attractiveness, notably the introduction of an optional liquidity window redemption mechanism and more flexibility in fund rules. The removal of access restrictions will make the framework more appealing, particularly for retail investors.  Numerous restrictions in the ELTIF framework were exclusively established to protect retail investors and are not necessary designed for professional and institutional investors, who are less in need of protection. Therefore, the proposed adjustments of selected fund rules for ELTIFs distributed solely to professional investors are welcome. In particular, the increased flexibility in portfolio composition and diversification requirements (including the broader scope of eligible assets) and concentration limits should also increase the attractiveness of ELTIFs for professional investors since the simplifications of the selected fund rules facilitate the implementation of more attractive strategies. Nonetheless, from the perspective of institutional investors, the attractiveness of ELTIFs is likely to remain limited. In many cases, the strictly regulated ELTIF design is less likely to meet individual investment needs than traditional alternative investment funds (AIFs), which can be implemented in a more flexible and tailored way. In particular, the ELTIF maintains its closed-end nature which limits its flexibility and attractiveness, which is why institutional investors, including insurers, will tend to opt for traditional AIFs in the future. The Solvency II Directive was amended by Commission Delegated Regulation 2016/467 when the ELTIF framework was set up to allow investments in ELTIFs to benefit from the same capital charges as equities traded on regulated markets, ie, lower than that for other equities (39% capital charge instead of 49%). Insurers are disappointed that the EC’s proposal does not include any changes to the equity capital charge under Solvency II to reflect ELTIFs’ long term nature and to allow companies to classify them as “long-term equity” and benefit from a 22% capital charge. Insurance Europe notes, however, that this would not preclude companies from using the look-through approach to the underlying investments.
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Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and American Chamber of Commerce to the European Union

15 Mar 2022 · Artificial Intelligence Act (AIA)

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

11 Mar 2022 · Solvency II

Response to Instrument to deter and counteract coercive actions by third countries

10 Mar 2022

Insurance Europe welcomes the opportunity to contribute to the European Commission’s consultation on the proposal for a regulation for an anti-coercion instrument (ACI). Insurance Europe strongly supports the aim of the proposal; the EU should be empowered to react when a third country adopts or threatens to adopt measures to pressure the EU or a member state into making a particular policy choice. However, the future regulation needs to be balanced and should not be used as a tool for the EU to achieve political objectives. The ACI should not be used as a protectionist tool and it is crucial that the EU remains open to international trade and investment. To that end, Insurance Europe believes that the following need to be ensured: -The proportionality approach of the ACI is of the utmost importance and it is positive that the regulation focuses on deterrence and prevention. This instrument should only be used as a last resort and only in the context of trade measures. -The future regulation should include a compensation mechanism for companies affected by third countries’ coercive measures. -This instrument should respect EU obligations and commitments under international law, in particular WTO commitments. Please find attached the detailed Insurance Europe views on the EC’s proposal for a regulation for an anti-coercion instrument.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness)

14 Feb 2022 · Retail Investment Strategy.

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

11 Feb 2022 · Solvency II, sustainable finance

Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)

13 Jan 2022

Insurance Europe welcomes the opportunity to provide feedback on the EC’s proposal on establishment of an Insurance Recovery and Resolution Directive. Please find below our general comments. The detailed Insurance Europe comments can be found in attachment. The EC’s proposals to implement a framework for recovery and resolution go beyond what is necessary given the extensive safeguards that are already in place to protect policyholders. The EC should strive to achieve a framework which is aligned with internationally agreed standards and should take care not to overburden insurers with unnecessary and costly requirements. In view of the specific characteristics of insurance business and the existing instruments under Solvency II, there is no need for such an extensive Insurance Recovery and Resolution Directive (IRRD). Applying a banking recovery and resolution style regime to the insurance industry without considering insurance specifics is not appropriate and could undermine the different resolution process of a failing insurer. For example, unlike banks, insurers do not regularly have to be resolved literally “overnight” as they can continue to rely on a steady premium income, assets remain available and their obligations towards policyholders become due over a longer period. This is because just a few, if any, insurers provide critical functions for which there is a need to ensure a rapid transfer and continuation. In addition, in contrast to banks there are very limited financial stability risks of failing insurers. The future IRRD to be implemented in the EU should fully align with international standards originating from the International Association of Insurance Supervisors (IAIS). In the interest of international competitiveness, it should not goldplate these standards to the detriment of the European insurance industry. Insurance Europe has identified the following key areas of concern with the EC’s proposals for an IRRD and continues to assess the impact of the proposals on European insurers with its members. - Scope - Safeguard integrity of supervisory framework - Shift of competence to EIOPA - Recognition of mutual undertakings Please find attached the detailed Insurance Europe views on the EC’s IRRD proposal.
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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

Insurance Europe welcomes the opportunity to provide feedback on the EC’s proposal for a Directive amending Solvency II. Please find below the key industry messages. The detailed Insurance Europe comments can be found in attachment. Solvency II (SII) has provided many of its intended benefits, including introducing a risk-based approach for solvency capital, setting very high standards for risk management and governance, extensive supervisory reporting and significant public reporting. As a result, the framework ensures very high levels of policyholder protection and a more level regulatory playing field across Europe. However, the framework needs a number of improvements because it does not correctly reflect insurers’ long-term business model, resulting in excessive capital burdens and solvency volatility for European insurers. It has also created a very significant, and in some cases unnecessary, operational burden for insurers. These deficiencies result in negative impacts for consumers, both directly through increased costs and less optimal investments and indirectly due to reduced product availability and guarantees. They also constrain the insurance sector’s ability to contribute to the EU’s political priorities, including economic recovery from COVID-19, the Capital Markets Union (CMU) and the European Green Deal, as they reduce the sector’s capacity to take risk. Finally, they undermine insurers’ international competitiveness, their natural ability to take a long-term approach to products and investment and their ability to avoid procyclical behaviour during a crisis. The SII review should not lead to a fundamental overhaul of the system. Instead, a limited number of focused changes are needed that will, in aggregate, lead to a justified and needed reduction in capital requirements and volatility. The right changes, as outlined below, will make the system more risk-based by better aligning it to the real risks faced by insurers. This will free up capacity for much needed investment, risk absorption and protection, while still keeping policyholders extremely safe. These corrections are necessary if the European insurance sector is to maintain its long-term business and product offering for the benefit of customers and financial stability, to play its full role in the transition to a sustainable economy and other EU political objectives, and to compete internationally. It is important that appropriate changes are made to both Level 1 and Level 2 of the current SII framework, as both play a key role in determining insurers’ capital and other requirements. In particular, elements that have a fundamental impact on capital requirements and resources should be specified in the Directive, for example the main extrapolation parameters. Please find attached the detailed Insurance Europe views on the EC’s proposal for a Directive amending Solvency II.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

7 Dec 2021 · Competition in insurance services.

Response to Revision of EU rules on Anti-Money Laundering (new instrument)

18 Nov 2021

Please find attached Insurance Europe's position paper on the Commission's AML legislative package. Thomas Gelin Senior policy advisor Insurance Europe is the European insurance and reinsurance federation. Through its 37 member bodies — the national insurance associations — it represents all types and sizes of insurance and reinsurance undertakings. Insurance Europe, which is based in Brussels, represents undertakings that account for around 95% of total European premium income. Insurance makes a major contribution to Europe’s economic growth and development. European insurers pay out almost €1 000bn annually — or €2.7bn a day — in claims, directly employ nearly 950 000 people and invest over €10.4trn in the economy.
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Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Response to New EU system for the avoidance of double taxation in the field of withholding taxes

25 Oct 2021

Insurance Europe welcomes the possibility to comment on this roadmap. Provisions around withholding tax procedures for cross-border portfolio investors or shareholders in the EU, which are different between member states, often pose a challenge to insurers in regard to cross-border investment, due to their complexity and the related costs. It is therefore important for the EC to improve their efficiency and effectiveness, without creating an excessive administrative burden in order to monitor and administer the withholding taxes paid. The following measures should be considered for a future reform of the EU withholding tax system: Acceleration, simplification and digitalisation of the relief procedure - It should be possible to submit applications for tax relief digitally to a central point of contact in the member state of the investor or shareholder respectively. The central point of contact would accept applications in the language of the claimant and would then forward the applications to the tax authorities of the source state (incl a residence certificate). The regulations on the VAT refund procedure could serve as a blueprint. - Procedures could be significantly accelerated by imposing maximum processing periods on the authorities of source states. In addition, interest should be charged on a refund amount if the application is not processed within the prescribed deadline, similar to the VAT refund procedure. - Procedures and forms, such as residence certificates, should be digitalised and standardised within the EU. Residence certificates should be unlimited or at least valid for the long-term, together with the obligation by the investor/shareholder to notify authorities about relevant changes in facts. Expansion of relief at source - A relief at source is preferable over the refund of withholding tax. A system of refund procedure is bound to be more cumbersome than a relief at source. - Introducing the TRACE procedure for portfolio investments throughout the EU would be helpful. Through the procedure, EU cross-border portfolio investors should be in the same position as if they had invested directly in securities. This could be achieved by (i) allowing the benefit of the local withholding rate or the rate applicable under a double tax avoidance agreement should it be lower and (ii) introducing a right to a tax credit in the domestic rules of the member state of the investor, where needed to avoid double taxation. Strengthening the EU principle of free movement of capital - There should be a common EU wide withholding tax reduction for certain investment funds. This would improve the level-playing field for cross-border investments. Source states sometimes tend to be reluctant to grant non-resident taxpayers the same benefits that resident taxpayers enjoy under their relevant national law. Consequently, foreign taxpayers cannot obtain the benefits granted by national law for a reduced withholding tax in the source state. Such discriminatory practices are against the principle of free movement of capital. It also results in economic double-taxation as the residence state would not accept a tax credit against the tax charge of the investor on the basis that withholding tax relief is available in the source state. -By initiating infringement proceedings, the EC could ensure that member states design their schemes in line with EU-law and therefore strengthen the EU-principle of free movement of capital. Withholding tax relief in relation to 3rd countries - Withholding tax relief measures should also be implemented for 3rd country cases, possibly coordinated by the OECD/Inclusive Framework Clarifications in the Parent-Subsidiary Directive and Interest&Licensing Directive - The scope of the reform should be widened to include intra-group payments (from controlling participations.) - The Parent-Subsidiary Directive should consequently be amended - interest payments/ license fees should fall under the I&L Directive
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Response to EU Standard for Green Bond

24 Sept 2021

The insurance industry welcomes the EC’s proposal for an EU Green Bond Standard (EUGBS) as a framework to facilitate capital flows to green and transition investments, in line with the Green Deal objectives. As Europe’s largest institutional investor, the sector supports measures to stimulate the development of the green bond market. Insurance Europe welcomes that the EUGBS: • Can help address the limited supply of attractive green assets and address risks related to greenwashing by providing a credible framework. • Captures the need to provide funding to sectors in transition to more sustainable business models. The provision on taxonomy-alignment plan is appreciated. • Aims to stimulate the issuance not only of corporate, but also of sovereign green bonds. Facilitating sovereign issuances is key to fund the EU’s transition and enhance the availability of attractive sustainable assets. • Is based on market standards and could become a global standard for green bonds, creating a level playing field for European investors. As capital markets and insurers’ investments are global, international collaboration is key to promote the use of the EUGBS by non-European issuers. • Is voluntary in nature and will not prevent the use of other sustainability bond standards. This avoids potential negative effects on the green bond market. • Includes clear reporting requirements. Easy access to reliable and usable information is key for investment decisions. However, Insurance Europe would like to highlight some improvements to ensure the uptake of the EUGBS: • Grandfathering — In the EC proposal, the designation of ”EUGB” is not maintained for the entire term of the bond through to maturity: if the taxonomy criteria change after issuance, the amended criteria need to be applied within 5 years. Such partial grandfathering can dampen investors’ interest. o Recommendation: It should be clear that outstanding EU green bonds, regardless of subsequent changes to the taxonomy screening criteria, remain EUGB. Once a bond is qualified as “green” at issuance, even if the screening criteria change and the bond no longer meets the new criteria, it should remain green for the entire term to maturity. If not, this will create uncertainty, confusion and market risk. • Taxonomy-alignment — For the EUGBS, the taxonomy has to be applied at project level, but the taxonomy is based on criteria at activity level. o Recommendation: Issuers need some discretion over how to align projects under a EuGBS with the activity-based screening criteria (ie how to apply the taxonomy at project level). Insurance Europe understands that issuers can follow existing market practices and rely on the TEG usability guide provided on the topic. • UoP for transition — Insurance Europe welcomes the alignment of eligible green projects with the taxonomy. This mitigates greenwashing risks. However, it is vital that EUGBS allows the financing of transitional projects. o Recommendation: It is key that the taxonomy is expanded and fully supports the transition. This will allow EU green bonds to finance a greater number of projects and help achieve the Green Deal objectives. To this end, issuers should have access to a broader taxonomy fully embedding the transitional aspect. EUGBS financing should be available for portions of projects when they act as enabler of a “green” project, are transitioning or are on track to comply with the taxonomy even if not yet captured in it (eg due to R&D nature, location outside the EU). • Accreditation — The accreditation should prevent the creation of monopolistic market structures, which increase issuance costs and act as barriers to green issuances. o Recommendation: The implementation of the accreditation criteria and supervision for EU GBS reviewers should not result in situations in which ESG agencies hold market- and price-setting powers, as in the credit rating market. The transitional registration should not make the issuance more complex.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

14 Sept 2021 · Solvency II

Response to Quick fix to the PRIIPs Regulation

9 Sept 2021

The European Commission’s proposal to maintain 1 July 2022 as the date the new Level 1 and Level 2 requirements apply to all product manufacturers, despite the delay in publication of the RTS, cuts the implementation period for the industry by more than 2 months. The proposed implementation period is too short, especially for new rules that relate to communication with investors and potential investors. To achieve better trust and understanding among investors and potential investors, the market needs time to adapt and get it right first time and avoiding confusion, to the detriment of consumers and Europe’s economy. Implementing changes involves numerous departments and competences to interpret the new requirements; gather new data; make actuarial and financial calculations; properly plan and make changes to IT; redesign templates; test the calculations and design; legally assess the narratives and figures; translate them; adapt training for staff and distributors; and implement new website disclosure requirements, etc. The many stakeholders in the value chain are involved in implementation. Many PRIIPs sold by insurers are MOPs that provide investors with a combination of different underlying funds. Where these are UCITS, insurers need the data and documents produced by UCITS providers to comply. As the new rules apply to both insurers and UCITS providers, MOPs providers will need sufficient time to collect the data from UCITS providers — once available - and update all their existing pre-contractual information for MOPs, update and store all KIDs on their websites, etc. This requires extensive dialogue between insurers and asset managers to agree the practicalities of data exchanges. Too short an implementation period could lead to poor implementation or force operators to suspend the distribution of certain products, which would be detrimental to consumers’ participation in the capital markets and trust in the information they receive. To ensure an orderly implementation, we urge for a 12-month implementation period from the adoption of the RTS proposals as the minimum time needed for all products and all market participants. A synchronised application date for all products (IBIPs, UCITS, MOPs, etc.) and providers (insurers, asset managers, etc.) for both the Level 1 and Level 2 amendments is key. In particular, Article 18 of the current PRIIPs RTS - which allows insurers to rely on the derogation in Article 14(2) of the PRIIPs RTS and to use the UCITS KIIDs for the provision of information on underlying funds for MOPs - is independent of any changes to the date of application of the UCITS exemption. The extension of the UCITS exemption will therefore not prevent Article 14(2) from expiring in December 2021, as currently stated in Article 18. This would pose significant practical difficulties for providers currently making use of the derogation in Article 14(2), as they would be required to produce their own PRIIPs KIDs for each underlying fund by the end of this year. This would also entail a substantial compliance burden for insurers and asset managers. They would need to produce entirely new data to populate the PRIIPs KIDs by a deadline that is much too short, and where the data simply could not be produced on time, the range of products offered to consumers would ultimately decrease. To ensure a consistent transitional regime across providers, the necessary legal certainty while UCITS remain exempted from the PRIIPs Regulation and a smooth implementation of the new PRIIPs RTS, we therefore reiterate the importance to align the expiry date of Article 18 of the PRIIPs RTS with the new end date of the UCITS exemption. As the scrutiny of the revised RTS by the co-legislators will take some time, we would also appreciate an expedited procedure by the co-legislators to facilitate publication in the EU Official Journal as soon as possible.
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Response to European Digital Identity (EUid)

2 Sept 2021

General comments Insurance Europe welcomes the opportunity to share the views of the insurance industry on the European Commission’s proposals for a European digital identity. Digital identities and the associated processes of authentication and authorisation are an essential component of the digital single market and of national and European economies, especially against the backdrop of the COVID-19 pandemic. Secure, easy-to-use digital identities, and their verification, that are available to all companies and EU citizens offer a high added value. Distribution The insurance industry welcomes the Commission’s initiative in this area and foresees a lot of potential in the insurance context. In the area of distribution, in particular, insurers could imagine the following use cases: - Clear and easy identification of potential customers, in particular in the fulfilment of “Know Your Customer” (KYC) obligations for online distribution channels or compliance with anti-money laundering requirements. - Facilitating the possibility to register and access insurers' online services and enabling easy identification for single sign-on (SSO). - Ensuring that prospective customers are of legal age and therefore have full legal capacity to enter into a contract. - In the context of the professional training and qualification requirements of employees, to demonstrate that relevant legal obligations have been fulfilled. The Digital Identity Wallet could provide a means of demonstrating to relevant supervisory authorities that continuing professional development requirements have been met by the employee. Technical implementation The draft Regulation requires Member States in Article 6a to issue a European Digital Identity Wallet under a notified eID scheme within 12 months after the entry into force of the Regulation. According to Article 6a(4)(c), the Digital Identity Wallets should meet the requirements set out in Article 8 with regards to assurance level “high”, in particular as applied to the requirements for identity proofing and verification, and electronic identification means management and authentication. Regarding the technical implementation of these provisions, the following aspects should be considered: - There is currently no uniform IT architecture, nor test catalogue for SSI-architecture. However, interoperability of Digital Identity Wallets, particularly with regard to their level of assurance, should be guaranteed. - Digital Identity Wallet solutions should also be user-friendly, while maintaining a high level of security and trustworthiness to improve users’ acceptance. - In terms of interoperability, user-friendliness and users' acceptance, users should not be forced to use different wallets depending on their respective scope. - There should be no technical restrictions on the use of wallets on mobile devices – wallet solutions should work smoothly across all mobile devices, regardless of their operating system or age. Data Protection One of the advantages of digital identities is that they could help to simplify the fulfilment of data protection rights and make them more secure. However, when deciding on a specific technology for the implementation of Digital Identity Wallets, care must also be taken to ensure conformity with data protection legislation (eg data protection by design) and to choose future-proof solutions. A solution that does not effectively take this into account may become subject to regulatory friction, which could slow down the uptake of trustworthy digital identities and prevent a quick rollout of much needed Digital Identity Wallets.
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

2 Sept 2021 · i) Revision of Solvency II ii) sustainable finance and related disclosure requirements iii) PRIIPs and retail investors needs.

Response to Requirements for Artificial Intelligence

6 Aug 2021

Insurance Europe welcomes the overall objective of the Commission to create a proportionate and principles-based horizontal framework of requirements that AI systems must comply with in the EU, without unduly constraining or hindering technological development and innovation. Moreover, insurers welcome the focus on the development of mandatory requirements for high-risk AI systems that pose significant risks to the health and safety or fundamental rights of persons. The introduction of harmonised rules on AI, however, requires a very clear and precise definition of an AI system. We understand that the Commission has based its definition on the OECD’s definition of an AI system, which it defines as “a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments”. While there is currently no universally agreed upon definition of an AI system, the OECD definition is an appropriate basis to use for any European approach, particularly given the inherently global nature of AI systems and the need to ensure consistency at the international level. The definition of an AI system as currently proposed in Article 3 of the draft Regulation, however, significantly widens the OECD definition by also including software within its scope. This will result in the inclusion in its scope of systems, techniques and approaches that should not be considered as AI and will generally create confusion and a lack of legal certainty. For example, the use of statistical output from a linear regression model in the actuarial function would be covered by this proposed definition, as would statistical approaches such as exploratory data analysis that mostly involves using graphical techniques to analyse datasets, or task allocation systems that form part of the back-office functions of companies. For this reason, not only should the general area of a system’s application be considered but also, on an individual level, its specific purpose. Furthermore, it should be stated clearly that the AI applications already referred to in Annex III also need to fulfil the conditions set out in Article 7(1) to be classified as high risk. In the context of its Framework for Classifying AI Systems, the OECD notes that “certain systems that use compute technologies and analyse data are not AI systems. If the system does not fit the definition of an AI system used in this framework, it is not considered an AI system. For example, Microsoft Excel is a system for data storage and analysis. The software allows users to store, sort, and run basic analysis on inputted data. However, it is not an AI system.” This is also true of a wide variety of other software types that may potentially fall under the proposed definition. The broad definition of an AI system that has been proposed in the draft Regulation should be narrowed to be fully aligned with the OECD and avoid running the risk of inconsistent and divergent classifications of AI systems. Insurance Europe also wishes to stress the importance of ensuring consistency not only with the OECD definition, but also with the definitions used in any existing or upcoming European texts that address AI, including in particular the forthcoming liability framework for AI. Article 33(8) proposes a requirement for notified bodies to take out appropriate liability insurance for their conformity assessment activities. It is insurers’ understanding that entities acting as notified bodies under the proposed Regulation and in a corresponding capacity foreseen by other EU legislation, for instance the Medical Devices Regulation, will continue to be able to cover all of their conformity assessment activities under a single contract of liability insurance. Further, it is insurers’ understanding that such insurance will be written on the basis of standard market terms and conditions in accordance with applicable insurance contract law.
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Response to Revision of Non-Financial Reporting Directive

12 Jul 2021

Insurance Europe is very supportive of the CSRD initiative. As Europe’s largest institutional investor with €10 trillion of investments, it is vital that consistent, comparable and machine- readable sustainability data is available so insurers can make appropriate investment decisions and comply to the European regulatory disclosure requirements (SFRD and Taxonomy). The CSRD will play a vital role to ensure that consistent and comparable sustainability data is available and, together with the ESAP initiative, can ensure the data can be accessed and used efficiently. The industry is particularly supportive of the following important aspects of the Commission’s proposals: Mandatory reporting in machine readable format, freely accessible by users. Data needed for Taxonomy and SFDR reporting prioritized and included into the first set of sustainability reporting standards (SRS) Increase in scope of companies covered - with large and listed companies having mandatory reporting and SMEs on a voluntary and potentially simplified basis Target timeline for first mandatory reporting in 2024 reporting on the year ending 2023 EU sustainability reporting standards will build on and contribute to standardisation initiatives at global level through constructive two-way cooperation between EFRAG and relevant international initiatives Limited assurance with a later review to consider if this should change to reasonable assurance Role of EFRAG to develop standards in consultation with stakeholders Option to publish sustainability reports at consolidated (group) level The industry notes however the following important elements where clarification/refinements are needed: There should be no decision now to move to automatically reasonable assurance. Given the very significant cost difference, an assessment if such a change is needed should be made after the CSRD is up and running. The current text makes the change to reasonable assurance automatic if standards for reasonable assurance audit are defined, however the decision to move from limited assurance should be separated from any decision to define audit standards. While the scope increase is welcome, the definition of large undertakings included in the draft text does not work for insurers because their balance sheet and revenue are fundamentally different from companies in other sectors. As a result, almost all SME insurers will be wrongly treated as large companies. For example, even a run-off insurer with a staff of 5 would be included as a large company under the current definition. One solution to this would be to apply only the employee criteria to insurers in order identify which non-listed insurers are large enough to be included under the CSRD scope. Insurers support the EC’s ambitious timeline and the need for rapid progress, but if it takes longer than hoped to finalise the EU sustainability reporting standards (SRS) then the time-table for reporting will also have to be adjusted to allow sufficient time for preparers to adapt systems and procedures and produce data of reasonable quality. Should there be any delays in the development of the SRS, the first set of requirements should focus on reporting information as defined by the SFDR and Taxonomy. Our full detailed response is attached to our submission.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good. For insurers, a greater availability of data could lead to improved risk monitoring and assessment, better customer experiences and increased fraud detection. The more data that is available for the common good, the better the digital solutions and analytical models will be. Individuals should be able to provide access to their personal data to a much higher extent than is possible today. There should, for example, be practical solutions that would allow individuals to exercise control over their own data, with appropriate consideration given to the security of sensitive data. For example, individuals should be able to grant third parties access to their data: for instance, if a customer decides that an insurance undertaking may access their driving data, the vehicle manufacturer should grant access on reasonable terms. The insurance industry also supports the overall approach set out by the Commission in its Data Strategy, which recognizes that sector-specific legislation on data sharing should only be introduced where market failures have been identified. The upcoming Data Act should therefore strengthen the framework conditions for data collaboration and partnerships. The data economy can only be successful if the different players involved have suitable means available to them to share and exchange data. Otherwise, important data will remain inaccessible, despite having the potential to reveal valuable new insights if re-used and recombined. At the same time, individuals and companies alike should have the choice to make their data available to others. It will also be important to establish a framework on how to exchange data between companies from a technical viewpoint, to ensure an appropriate anonymisation of data to protect privacy. This would help to further encourage research and development, as well as the creation of anonymised data sources. Insurance Europe also welcomes the Commission’s objective of establishing more competitive markets for cloud computing services. Insurers have reported difficulties concerning the concentration of cloud service providers, which results in high levels of market power and an imbalance in the negotiating power between the parties. This becomes a particular challenge in the case of SMEs. The concentration of market power among a few large cloud providers also contributes to the limited possibility to switch providers and standard terms and conditions that are offered on a take-it-or-leave-it basis.
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Response to Supervisory data strategy

14 Jun 2021

The industry fully supports the aim of the supervisory data strategy to initiate a shift to a modern, efficient and effective approach to data collection for supervisory purposes. At the same time, the following points should be considered: APPROACH *The approach should work for all stakeholders and benefits should outweigh costs. CONTENT AND IMPLEMENTATION *The principle of proportionality should always be taken into account. Any sharing of data with supervisors must be carried out in an efficient and proportionate manner in line with regulatory requirements. The EC must therefore be clear about the benefits and objectives of the proposed changes. Furthermore, the responsibility for data shared and its potential use by supervisors regarding an undertaking’s governance, processes and obligations must be clearly defined, especially when that information could potentially lead to supervisory interventions. *Existing reporting timelines should be respected. *The strategy should provide reporting relief and operational benefits for insurers. Given the objectives of this initiative, the overall ambition should be to reduce the supervisory reporting to the essential data. Furthermore, there should be no duplication of data already reported within other frameworks, to NCAs, both national and European. The use of technology could allow supervisors to deliver innovative and efficient supervisory solutions that would support a more effective, flexible and responsive supervisory system. For example, technological solutions could potentially facilitate the sharing of annual/quarterly reporting data with supervisors. Any such data exchange should come with reporting relief and operational benefits for insurers. The advantages of the European Single Access Point (ESAP) initiative — which should make data easily accessible, standardised and free of charge, and reduce ad hoc data requests from various stakeholders — should also be considered. *Reporting requirements changes should be minimized, communicated timely and allow sufficient time for implementation. Any change entails large costs and effort for insurers, who have already invested significantly to implement Solvency II reporting. Further changes — eg aligning reporting systems for different legislations — could therefore require substantial investments. The timely communication of future changes and the allowance for a longer implementation time is therefore crucial. The industry should also be consulted on the required data, the format and any technology requirements and, to the largest extent possible, these should be kept constant over time. *Timing Changes to reporting requirements proposed in the context of the review of Solvency II should be aligned with the timeline of the supervisory data strategy. The supervisory data strategy plans to consider a number of co-ordinated sectoral and horizontal measures, that would be implemented over the coming years. An extensive review of Solvency II is however currently taking place, in which the European Insurance and Occupational Pensions Authority (EIOPA) is proposing many changes in regard to reporting, which are also expected to be implemented over the coming years. In fact, EIOPA is planning substantial changes to the Solvency II quantitative reporting templates (QRTs) to be implemented as from 2022. EIOPA should therefore not act on any of its proposals before proper Level 1 and Level 2 strategic consideration of the issues (including full scrutiny by the EU institutions) has taken place. This would avoid having to change the QRTs and insurers’ IT-systems several times. In fact, it would be advisable to align the changes foreseen in the context of the review of Solvency II with the timeline of the supervisory data strategy, as this would avoid unnecessary costs and efforts. STAKEHOLDER INVOLVEMENT *It is important to keep the industry and stakeholders involved in the further development and
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Insurance Europe appreciates the possibility to provide comments to the European Commission draft proposal for a Delegated Act supplementing the Taxonomy Regulation. The industry is supportive of the proposal. In particular, it appreciates that: The proposed timeline (application in 2022 with full reporting in 2023) will help allow FMPs time to implement the necessary IT, data, validation and management processes. However, we note that: The disclosures set out in Article 11.2 a-d would still require significant implementation efforts and therefore ask the Commission to consider the cost-benefit of requiring this information a year ahead of the actual KPIs and related qualitative information. As the timetable applies to all companies, FMPs still face a sequencing problem because they require the taxonomy related data from other companies in order to fulfil their own taxonomy reporting obligations. The EC should clarify how FMPs can solve this issue. At the very least it should be made clear that a reasonable effort basis (eg estimations) is acceptable, especially for first time reporting for FMPs. It should be explicit that it is acceptable for FMPs to use latest available data for their reporting (which will typically be from the previous reporting year). The alignment with the investment disclosures for asset managers and insurers, as they improve the consistency and comparability of the KPI across FMPs. Similar language should be used for the investment KPI to ensure a level playing field considering that this information will also be disclosed for non-professional public (e.g. the term “Green Asset Ratio” is proposed only for credit institutions). There are many financial institutions that have mixed activities. In case of reporting for the consolidated entity, a consolidated format should be established. More alignment between the various templates is also desirable. Sovereign exposures are excluded from the main indicator because they are not (yet) covered by the taxonomy. The plan to include these in the taxonomy by 2025 is welcome as these assets are extremely relevant for insurers. Additional complementary KPIs will be used to provide more detail, including information on assets currently not covered by the taxonomy and therefore not included in the main KPI. The KPI numerator for underwriting activities, based on premiums, can be assessed at product level (although DNSH will still require customer level assessment, we recognise why this is unavoidable). The industry sees some need for further refinement in order to ensure the disclosures are fully meaningful and efficient for information users, while achieving consistency with ongoing work on sustainable finance. With respect to KPI for investment activities: 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: Investments where the policyholder make the choice of where to invest. These should be reported separately as a secondary KPI. This exclusion would provide a more accurate picture of the share of investments where the insurers are responsible for the investment allocation, and therefore for the taxonomy alignment. In the current text, such investments are referred to as where the policyholder bears the risk but, while this is often aligned with investments where the policyholder chooses the investment, this is not always the case. Therefore, the wording should be “where the policyholder chooses the investment”... (our full response can be found in the document attached)
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 May 2021 · Solvency II, green recovery

Meeting with Mairead McGuinness (Commissioner)

28 May 2021 · Record video for Insurance Europe Resilence Week touching all aspects of insurance role in building resilence.

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

30 Mar 2021 · Solvency II

Response to Revision of the NIS Directive

18 Mar 2021

Insurance Europe welcomes the opportunity to provide feedback on the proposal for a revised NIS Directive. Insurance Europe's position can be found attached.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

3 Mar 2021 · Insurance policy

Meeting with Mairead McGuinness (Commissioner)

25 Feb 2021 · Solvency 11

Response to Digital Operational Resilience of Financial Services (DORFS) Act

22 Feb 2021

Insurance Europe welcomes the opportunity to provide feedback on the DORA proposal. Please find Insurance Europe's position attached.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

17 Feb 2021 · Solvency 2

Response to Digital Levy

11 Feb 2021

Insurance Europe welcomes the possibility to comment on the roadmap for the introduction of a digital tax to address the issue of fair taxation of the digital economy. Key points - While data is important for insurers and reinsurers, and they use data from different sources, (re)insurance is not a highly digitalised business model. -The distribution of taxing rights between countries is an issue that should be tackled globally, otherwise third countries may impose tariffs as a countermeasure against the EU. Insurance Europe views favourably the reference to the work that is currently ongoing at the OECD on the issues of profit allocation and nexus. In view of that, the timetable foreseen seems very ambitious. Any rushed proposals that could lead to overlapping with the OECD outcome and to double taxation should be avoided. To be compatible and to avoid layering additional taxes, the proposed options should be based on the OECD solution agreed. Scope The industry believes that the definition of the scope is very important for an accurate assessment of the tax base. A possible taxation of digital businesses and/or activities should not hinder the ongoing digitalisation of the economy. It is necessary to limit the scope of the new tax rules, as well as the administrative burdens companies must bear. Insurance Europe would like to point out that most of the problems identified by the inception impact assessment and which the initiative aims to tackle do not affect (re)insurance. Insurance is a well-developed, diversified market with intensive competition rather than one or two dominant players, making market concentration highly unlikely. Regulation and capital The insurance and reinsurance business models have specific characteristics that already make possible taxation in the location in which the value of the business is created. Each risk-bearing entity within a (re)insurance group operates as a separate legal entity and is regulated by the home state regulator in order to be able to operate throughout the EU using EU passporting. For insurance, most of the business is local and where there is cross-border insurance and reinsurance, regulation requires capital to be located with the risk. In most cases the business model is based on companies with a local physical presence, as companies need a local market presence for market access, to enable them to be close to customers and brokers and meet the regulatory requirements to sell insurance. Therefore, it would not be possible for (re)insurers to benefit from “scale without mass” and not pay corporate taxes in all jurisdictions in which they have a significant economic presence. Consequently, when it comes to insurance business taxing rights are already fine-tuned to the jurisdictions of the consumers. Premium taxes The purchase of insurance is already subject to indirect taxes based on location of risk (which often coincides with the location of the user), such as premium taxes. While these are levied on insureds, the economic costs of premium taxes are significant for the whole industry. Insurers are also one of the main payers of stamp duties or financial transaction taxes that arise on their asset portfolios in many EU member states. The digital levy would add just another layer of revenue-based taxes. Generally speaking, the underlying policy rationale of making certain digital companies pay their “fair share” of taxes is understandable, however there may be doubts about whether the use of a revenue-based tax that is not necessarily linked to the profit or income of the digital company can be viewed as “fair”. Impacts Insurance Europe would also like to highlight that any additional taxation is likely to result in increased costs for end-consumers.
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Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

General comments Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good. The creation of an EU-wide governance framework for data access and use, in particular for the re-use of certain types of data held by the public sector, for the provision of services by data-sharing providers to business users and to data subjects, as well as for allowing individuals to consent to greater access to their data for the common good, will help to improve data sharing and should be seen as a positive step. This, together with the development of common European data spaces, will contribute to ensuring a future-proof, innovation-friendly framework that supports data-driven business and enables the digital transformation of society, while ensuring appropriate protection for consumers. However, much depends on the exact form that such a framework will take. For insurers, greater availability of data could lead to improved risk monitoring and assessment, better customer experience and increased fraud detection. The more data that is available for the common good, the better the digital solutions and analytical models will be. Insurance Europe agrees that individuals should be able to allow access to their personal data to a much greater extent than is possible today, ensuring that they can exercise control over their own data and with appropriate consideration given to the security of sensitive data. Individuals should be able to grant other parties access to the data generated by them: eg if a customer decides that an insurance undertaking may access their driving data, the vehicle manufacturer should grant access on reasonable terms. In this respect, Insurance Europe welcomes the acknowledgement by the Commission that sector-specific legislation can add new and complementary elements to this data framework, such as the envisaged legislation on the European health data space and on access to vehicle data. At the same time, the insurance industry supports the overall approach set out in the EC data strategy, which recognises that sector-specific legislation on data sharing should only be introduced where there are identified market failures; the focus should otherwise be on strengthening the conditions for data collaboration and data partnerships. It is important that the development of common European data spaces creates a common understanding between industries with regard to data specification, update frequencies, governance, data quality, enforcement, etc. The alternative may result in a patchwork of unrelated, non-interoperable databases that offer no real benefit. Specific comments Insurance Europe's comments on specific aspects of the proposal - data intermediaries, data altruism and the European Data Innovation Board - can be found in the attached position paper.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Jan 2021

Please find below a summary of Insurance Europe's comments on the EC inception impact assessment on a single EU access point for company information. Our detailed comments can be found in the attached position paper. Insurance Europe supports the European Commission’s plans to establish a European Single Access Point (ESAP) for financial and non-financial information disclosed by companies and welcomes the opportunity to comment on the inception impact assessment. The comments below focus primarily on the aspect of environmental, social and governance (ESG) data, which is the priority for the industry given existing issues with the availability, reliability and comparability of ESG data for investors. It is important that the wider scope beyond ESG data does not slow down the availability of ESG data within the ESAP. Insurance Europe has the following comments on the establishment of the ESAP: - The data included in the ESAP must be fully aligned with the regulatory requirements set by the SFDR, Taxonomy Regulation and NFRD. - As another building block, the register should include relevant ESG information already collected by European and national institutions such as governments, central banks, statistical bodies, etc. - Beyond what is required to comply with regulatory requirements, care should be taken to ensure that the benefits outweigh the costs. - The materiality of disclosures should be taken into account to avoid unnecessary costs and proportionality more generally should be fully taken into account, with the size and complexity of undertakings considered when developing guidance or requirements. - With respect to sustainability research and ratings, the ESAP can help minimise related costs and avoid market participants being forced to rely on third-party providers. In addition, it can help improve transparency about ESG data and enhance the comparability and reliability of research and ratings. - Beyond sustainability data, research and ratings, credit rating databases are also needed by insurers to comply with certain regulations (eg Solvency II). However, they can currently be excessively expensive for insurers to access/use. If the scope of the ESAP goes beyond ESG data, the EC should consider how credit ratings could be included into it as a way to address this issue. - In the context of the post COVID-19 recovery, it is key that it also enables digital transformation, which in turn can help embed sustainability in the financial sector. EU policy action will be crucial to maximise the potential of digital tools for sustainable finance. Any proposed regulatory actions should be innovation-friendly and technology neutral to ensure that they are fit for the digital age and do not create any obstacles to innovation.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

13 Jan 2021 · Artificial Intelligence

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Non-life insurers have factored sustainability considerations into their business for a very long time. As risk managers, risk carriers and investors, insurers have a fundamental interest in sustainable economic and social development. By insuring crucial infrastructure and buildings against natural catastrophes now made worse by climate change, insurers already contribute significantly to the EU’s sustainability agenda. Whilst the underwriting process differs from one insurer to another, sustainability factors are at the core of the underwriting process of all insurers. In line with this longstanding commitment to sustainability, Insurance Europe supports the Commission’s effort to create a common language for investors when investing in economic activities that have a positive impact on the climate and the environment, including non-life insurance. However, this common language must reflect the incredibly heterogenous nature of the European non-life insurance business. The wide variety of business lines, insured businesses, types of companies and products make this exercise much more complex for non-life insurance than any other sector covered by the EU Taxonomy. The proposed screening criteria are not yet up to this challenge. As a general observation, Insurance Europe notes that the Commission attempted to capture all perceived good practices within its criteria and, in doing so, listed criteria applying at product- as well as company-level. This makes it very difficult to comply with the criteria. Therefore, non-life insurers urge the Commission to only include company-level criteria in this delegated act. The Commission should also further consider the causal link between the proposed criteria and the desired goal, ie whether each specific criterion is relevant to deciding whether an economic activity contributes substantially to climate change mitigation or adaptation. For example, it is not clear how the public disclosure of loss data (“Loss Data Sharing” criterion) is relevant to the activity’s contribution. We attach our detailed feedback on the activity description and criteria.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

16 Dec 2020 · PRIIPS

Response to Review of the VAT rules for financial and insurance services

19 Nov 2020

Insurance Europe welcomes the possibility to comment on the Roadmap/Inception Impact Assessment for the review of the VAT rules for financial and insurance services. We believe that an effort is required to harmonise VAT rules across Europe, establish a level playing field on VAT for all financial services providers, create legal certainty and ensure that European VAT law is fit and proper for the modern business environment. The modernisation of the value-added taxation of insurance services must not jeopardise the attractiveness of private pension provision. We are pleased to note that the initiative aims to tackle the lack of VAT neutrality, legal uncertainty and regulatory complexity, although the roadmap does not set out very clearly whether the introduction of a (partial) tax liability is also being considered for insurance services and its details. Insurance Europe believes that the current Directive is outdated and not correctly applicable to modern financial services. Recent rulings of the CJEU have shown a need to adapt the VAT Directive to current market realities; CJEU rulings are an inefficient means of providing certainty in the European VAT system. Due to this lack of adaptation to modern financial services, member states endeavour to find a balance in their national markets and may implement their own interpretation of the law. This results in an uneven playing field within the EU, causing VAT to become a key factor affecting the competitiveness of the EU and a driver in business decisions for financial services companies. It also leads to inappropriate taxation of financial services providers and lost VAT income for member states. Irrecoverable VAT is also a considerable cost for businesses, which in turn is largely passed on to customers. In several countries, they must also pay IPT, meaning that in effect they face double taxation. The interaction of VAT with the different national tax regimes for financial services must be carefully examined (eg consider the repeal of IPT if a tax liability for insurance services were introduced) to ensure a level playing field in the interest of policyholders and avoid any increase in the costs of insurance contracts. We also believe the lack of harmonisation of VAT across the EU is a significant barrier to a Capital Markets Union. VAT rules should have a very clear scope that includes all transactions that contribute to the provision of insurance services. Insurance Europe believes that: - It is necessary to review the VAT Directive to explicitly allow Cost Sharing Groups independent of the type of activities conducted by members of the group. - More clarity and legal certainty are needed for financial and insurance services operators about the scope of the VAT exemptions that apply to the industry. - The VAT Directive should be amended to make the option of VAT group treatment mandatory in every member state’s legislation to avoid any distortion between financial operators located in different member states. - The VAT Directive should be amended to include the cross-border effect for VAT groups to avoid any distortion between financial operators located in different member states and in line with the CJEU ruling in Case C-386/14. - The elimination of VAT obstacles should apply to the arrangements necessary to carry out insurance business, such as those under European directives. These features should be determined by the nature of the service provided, rather than by the person providing it. Outsourced services that are necessary to insurance business, such as claims-handling and leading fees in coinsurance business, must benefit from a VAT exemption; otherwise a true level playing field would not be achieved. Insurance Europe looks forward to contributing to the consultation in 2021 to set out in more detail our position and provide further comments on the areas in which the Directive needs to be modernised.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

10 Nov 2020 · Introduction and discussion Solvency II review

Meeting with Andrea Nahles (Cabinet of Commissioner Nicolas Schmit) and EuroCommerce and

19 Oct 2020 · Social dialogue

Response to Long Term Investment Funds – Review of EU rules

14 Oct 2020

The European insurance industry supports the European Commission’s intention to make improvements to the European Long-Term Investment Funds Regulation (ELTIF) framework, as indicated in its Capital Markets Union (CMU) Action Plan (Action 3). The insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, for the benefit of its policyholders. Therefore, it welcomes a revision of the ELTIF framework that has the objective of making these investments more attractive for institutional investors. Because the ELTIF legal framework was designed for a wide range of investors, ELTIFs offer institutional investors less flexibility and their design is less likely to meet individual investment needs than other alternative investment funds. Therefore, the industry supports the Commission’s proposals to reduce barriers in the ELTIFs legal framework and to widen the retail investor base in line with the objectives of the CMU. Specifically, the industry encourages the Commission to make refinements to the framework to remove restrictions that prevent any significant interest from the insurance industry. Key improvements are needed for the ELTIF to become attractive to institutional investors, while at the same time offering attractive long-term investment opportunities to retail investors in line with the objectives of the CMU Action Plan. A way to increase the attractiveness of ELTIFs for institutional investors could be to introduce different rules for ELTIFs tailored to institutional investors on the one hand and private investors on the other. This would require revisions to: Fund design: ELTIFs should not be limited to closed-end funds. They should be able to offer regular subscription and redemption possibilities at appropriate frequencies. Portfolio composition and diversification: A refinement of the framework is needed to provide more flexibility and targeted investor protection, in particular for thresholds on portfolios of financial instruments and in regard to the strict and restrictive diversification requirements. Eligibility of investment assets: The scope of eligible assets must be expanded to allow for better diversification and liquidity of the fund. In practice, the ELTIF must be sufficiently flexible to allow fund managers to design a structure and, in particular, investment strategies suitable for the needs of its targeted investors.
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Response to Requirements for Artificial Intelligence

10 Sept 2020

Insurance Europe welcomes the initiative to encourage ethical and responsible development of AI in the EU and supports the creation of an ecosystem of trust to stimulate its uptake. A European approach is necessary to limit fragmentation of the digital single market, ensure fair competition and protect European citizens & businesses. As noted by the Commission’s HLEG on AI in its recommendations, the development & use of AI is already covered by a wide body of existing EU legislation, such as on fundamental rights, privacy & data protection, as well as product safety & liability. This is further complemented by national & sectoral regulatory frameworks. A horizontal, proportionate, principles- and risk-based framework that builds on this, addressing potential gaps where necessary, will help support the development & uptake of AI and avoid unnecessary burden. We believe that option 1 would therefore be the preferable policy option, as it provides for a soft-law approach to facilitate and spur industry-led intervention. It would also be the most relevant approach to encourage coordination on a single set of AI principles, while enhancing enforcement of existing rules. To promote the uptake of AI & prevent innovative technologies from being stifled by premature regulation, the ethical use of AI should be supported by, and reinforced through, voluntary and/or non-legislative instruments as far as possible. Voluntary certifications have traditionally proven to be an effective means of ensuring high & transparent standards (eg in the area of IT security). They enable customers to easily identify trustworthy products and allow companies to demonstrate and promote the quality of their products. Many companies would have an interest in voluntarily opting to certify their AI applications to enhance consumer confidence, stay ahead of the competition and demonstrate compliance with current standards and regulation. Moreover, an approach that focuses mainly on voluntary instruments (eg industry-developed codes of conduct or guidelines) remains compatible with the option to introduce legislative instruments containing mandatory requirements for certain AI applications, as set out in option 3. However, it is important to ensure that any EU legislative instrument that may be introduced is horizontal, proportionate & risk-based, and limited only to “high-risk” AI applications that are determined on the basis of clear criteria (as suggested in White Paper). Inclusion in the scope of such requirements of low-risk, common automation processes or applications that pose little or no risk to the rights of customers would hinder innovation and the uptake of new technologies, give rise to additional costs, and create a disproportionate burden in view of their low risk. From the outset, the insurance industry has made extensive use of data and algorithms, eg in the calculation of insurance premiums. Such methods of analysis are long-established and already subject to supervision. The development of AI tools can help insurers to improve underwriting as well as to better monitor & predict risk, and thereby advise policyholders on how to reduce risk, which can in turn help reduce the frequency and severity of losses over time. We would also stress that monitoring the use of AI applications should continue to fall within the competence of the relevant sectoral supervisory or regulatory authorities, as they remain best placed to understand the market in question and the specific context of the AI application vis-à-vis the applicable regulatory framework. The existing liability regime (PLD) is fit for purpose to address the risks posed by AI but could benefit from additional guidance in certain key areas. Existing product safety legislation should be reviewed as to its fitness. New legislation should only be adopted where clear evidence demonstrates a need for action and should be proportionate to the concrete risks posed by the AI application in question.
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Response to European Digital Identity (EUid)

3 Sept 2020

Insurance Europe welcomes the evaluation of the 2014 eIDAS Regulation and accompanying revision of the current legal framework. Digital identities and the associated processes of authentication and authorisation are an essential component of the digital single market and of national and European economies, especially against the backdrop of the COVID-19 pandemic. Secure, easy-to-use digital identities, and their verification, that are available to all companies and EU citizens offer a high added value. Digital identities could, for example, help to simplify the fulfilment of data protection rights and make them more secure. The right of access is the basis for all other existing data subject rights. However, before providing any information to a data subject, the controller must ensure that the person requesting the information is actually the person concerned. Otherwise, there is a risk of a data protection breach leading to sanctions. To protect themselves, companies are sometimes forced, depending on the sensitivity of the data, to put in place cumbersome procedures to determine the identity of the contact person. This in turn may be perceived by those affected as a deliberate attempt to delay or prevent the assertion of their rights. Therefore, the promotion and strengthening of digital identities - especially in cross-border processes and against the background of a digitally sovereign Europe - as well as a close partnership with business, is to be welcomed. Recent technological and political developments, such as the increasing dependence on online business, must also be duly taken into account. Insurance Europe believes that the extension of the legal framework to the private sector is to be welcomed in principle. However, this should not create a regulatory burden on companies. Double regulation and a lack of proportionality, which could have a negative impact on everyday business, should be avoided. With the expansion to the private sector, a simultaneous recognition of private eID solutions in eGovernment would be desirable. It should be noted that the legal framework should create harmonising framework conditions but should in no way reduce the efficiency of innovative solutions and business processes. Digital identification processes should be secure and compliant with data protection legislation but should not be subject to any higher legal requirements than non-digital solutions. The insurance industry generally welcomes the introduction and voluntary use of a European digital identity system (EUid), as a supplementary eID solution, especially for cross-border processes. However, there is a need for further clarity over the exact regulatory and technological implementation of such a system. It would therefore be important to involve industry from the start in the development of any EUid scheme. The liability for trust service providers is already partially harmonised by the current legal framework of the eIDAS Regulation (Article 13), so it is questionable as to whether further harmonisation of liability is necessary and suitable to achieve the stated goals. Any efforts that seek to strengthen digital economic activity in Europe are to be welcomed, particularly in light of the changing geopolitical environment. Insurance Europe wishes to highlight that some of the issues referred to in the roadmap leave unanswered questions or require further discussion or clarification. Overall, however, subject to further details regarding the precise content and the implementation of the proposals, Insurance Europe would support a combination of the three policy options put forward by the Commission, ie improving the functioning of the eIDAS Regulation, extending its reach to the private sector and creating an EU-wide digital ID (EUid).
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Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)

26 Aug 2020

We welcome the EC Inception Impact Assessment and agree to a significant extent with its objectives and policy options. However, there are some key omissions and some refinements that are necessary to ensure the right outcomes Solvency II (SII) is strongly supported but is excessively conservative and has some measurement flaws and excessive operational burdens that create unnecessary costs and barriers, in particular relating to the provision of long-term products and investments. The SII review should not lead to an increase in capital requirements and for certain products a better reflection of the real risk will lead to a justified release of capital. This outcome is necessary for insurers to continue to provide long-term products and fulfil their role in supporting recovery, sustainable growth and transformation to a net-zero carbon economy On objectives and policy options: Objective 1 is supported. However, while mitigating artificial volatility is key, two other elements should be added: ensuring insurers’ liabilities are not exaggerated, especially long-term liabilities, and ensuring capital charges for investments are appropriate. Given concerns that SII can overstate liabilities and some capital requirements and create artificial balance sheet volatility, it should also be made clearer that policy options that result in justified and needed reduction in overall capital requirements will be considered Objective 2 is supported In objective 3 there is no need to enhance protection since SII, when implemented appropriately, offers sufficiently high protection. The focus should be on ensuring SII is applied appropriately and on supervisory coordination of FOS/FOE. Instead of harmonising IGS, member states should have flexibility to choose features that best suit their market Systemic risk is limited for the insurance sector and SII is already very comprehensive. Any new measures should be limited to applying the IAIS holistic framework, avoiding procyclicality and should not go beyond the EC CfA We do not support non risk-based reductions in capital requirements as incentives to address climate change. Removing SII barriers will create strong enough incentives when combined with insurers’ own natural interest and business model together with the EC’s powerful regulatory initiatives (SFDR, Taxonomy, NFRD) and the wider EU Green Deal Two objectives should be added: Ensuring the international competitiveness of the European industry. SII is extremely conservative due to the measurement flaws and overall approach to calibration. Other jurisdictions appear to take much greater account in the design and calibration of their regulatory frameworks of the special characteristics of insurers’ long-term business model as well as of their economic and social goals Simplifying & streamlining reporting requirements, in line with the EC’s fitness check of supervisory reporting requirements On economic and social impact: The EC indicates that strong industry capitalisation means that increasing capital requirements (eg for interest rates) would not have an adverse impact. This is wrong because even if it appears an insurer can “afford” a capital increase, the absolute level of capital remains important and artificial volatility creates a need for high buffers. Insurers typically allocate capital to products when assessing which products and related investment strategies are viable and how much they need to charge customers. Projecting even lower risk free rates or increasing SCR for interest rate risk shocks can have significant negative impacts including hindering insurers’ ability to offer products with long-term guarantees and pushing them to shift risk to policyholders On impact assessment: It is vital to fully understand and measure the cumulative effect of policy options (capital and operational costs) at jurisdictional and aggregate EU level and against both normal and stressed market conditions
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Response to Implementing act on a list of High-Value Datasets

24 Aug 2020

Insurance Europe welcomes the objective of this initiative to ensure that a common EU-wide layer of public sector datasets is easily and freely available for re-use, which can lead to significant benefits for society, the environment and the economy. Public institutions can provide invaluable sources of data due to their comprehensiveness and the quality of the datasets. However, one of the major challenges faced by insurance companies when developing their AI systems, for example, is the restricted or limited access to data from the public sector. Very few countries in Europe have a regulatory framework for data sharing with companies, while some jurisdictions are further limiting access to the data stored by their public institutions with a consequent negative impact on innovation. Insurance Europe therefore shares the Commission’s view that the establishment of a list of high-value datasets, to be made available free of charge and without restrictions is a good way to ensure that public sector data has a positive impact on the EU's economy and society. Another challenge in this context is the methodology used by public institutions to compile data. For maximum societal benefit, such public sector datasets should be made available in a machine-readable format that would facilitate their subsequent use in a variety of data-driven applications. In addition, technical issues such as interoperability and standardisation of data should be addressed in order to ensure that such datasets can be used to their full extent. It should also be noted that the data needed for some AI applications can be highly concentrated among a small number of entities with dominant market power, raising questions as to how access to non-personal data in private hands should be governed. The insurance industry’s dependence on third-party providers or vendors for datasets can result in insufficient access to data that would otherwise help to improve AI systems and better serve customers. Insurance Europe is therefore encouraged that the Commission intends for high-value datasets to also act as reference data for other (public or private sector) data and encourage the re-use of such related data (eg high-value public geospatial data bundled with data derived from sensors or mobile devices/cars).
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Aug 2020 · Packaged Retail and Insurance based investment products regulation

Response to Action Plan on the Capital Markets Union

4 Aug 2020

Please find below the Insurance Europe general comments. Our detailed comments are attached. Insurance Europe welcomes the objectives set out by the EC in the roadmap. The insurance industry stresses the importance of taking into account in the design of the Action Plan the following priorities identified by the sector: Address regulatory barriers to long-term & sustainable investment: -Focused improvements to Solvency II (SII) are necessary to support insurers fulfilling their key role in supporting EU’s investment needs. Improving the treatment of long-term business & investment under SII is key. The SII review needs to be ambitious, yet targeted. This includes improvements to the Risk Margin & Volatility Adjustment as well as changes to the equity& debt capital charges. It is also important to maintain the existing extrapolation method& parameters. -Ensure that IASB provides an appropriate solution for the ‘recycling issue’ under IFRS 9. Increase availability of suitable long-term & sustainable assets: -Policymaker action is needed to stimulate the supply of assets that meet sustainability criteria & quality and security requirements. The EC retail strategy should: -Address consumer information shortcomings resulting from EU legislation: Simple & accurate disclosures allow consumers to make informed investment decisions & facilitate participation in the CMU. Legislative reforms must be adequately tested& evidence-based to ensure better outcomes for retail investors. Rushed changes to the information provided to consumers would only confuse them and undermine trust in financial services. The recognition by the CMU HLF of the shortcomings of the PRIIPs Regulation is welcome. -Ensure legislation is appropriate for all providers & respects different sectors specificities: Participation in the CMU will be enhanced through regulation that accommodates the specific features of insurance products & distribution systems. Rules on advice & inducements must be workable for all participants including smaller, local distributors who often are the point of access for retail customers. -Ensure technology-neutral legislation that is digital & innovation friendly, future proof & ensures a level playing field among market participants. -Improve financial literacy by: encouraging national financial education strategies & incorporation of financial literacy in school curricula; encouraging the creation of national pension tracking tools; introducing a European Day of Financial Education & an EU retirement week. Promote pensions savings& long-term growth: -Encourage participation in complementary occupational & personal pension schemes: Further Member State action is needed to promote well-balanced multi-pillar pension systems built on adequate, stable and attractive regulatory frameworks & tax treatment. -Ensure the PEPP is attractive to buyers & sellers: The success of PEPP will depend on many key issues still need to be addressed by EIOPA & the EC in implementing regulation. Whether PEPP will channel savings into long-term investments will depend on its attractiveness to savers & distributors alike Preserve trust in the existing regulatory framework& in the reliability of the financial sector: SII already contains measures to preserve capital levels, on the basis of a case-by-case assessment. Intervention from NSAs& EIOPA to impose additional measures for the whole sector deviates from the EU risk-based regulation, creates distrust and undermines the ambition of a CMU. Eg, dividends distribution is an important element of the investment decision and NSAs are able to prohibit distribution in cases where solvency is an effective & proven concern. Promote global competitiveness: Ensure that proposed actions consider the competitiveness of the (re)insurance industry as a global market player. Promote cross-border investment facilitation: Improve efficiency & effectiveness of national insolvency proceedings& withholding tax procedures.
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Response to Legislative framework for the governance of common European data spaces

29 Jul 2020

Insurance Europe welcomes the overall objectives set out in the roadmap, namely: - to make more data held by the public sector usable for research and innovative uses (ie development of new products and services); - to allow individuals to consent to greater access to their data for the common good; and - to enhance overall data use in the economy by lowering transaction costs, addressing interoperability and standardisation, and facilitating voluntary data sharing. These policy objectives, and the general idea behind common European data spaces, are positive steps, and will contribute to ensuring a future-proof, innovation-friendly framework that supports data-driven business and enables the digital transformation of society, while ensuring appropriate protection for consumers. However, much depends on the specific mechanism or instrument that is chosen, as the nature of certain policy options is not sufficiently clear at this point, eg the creation of European coordination bodies or “structural enablers”, or a common European consent form. For insurers, a greater availability of data could lead to improved risk monitoring and assessment, better customer experience and increased fraud detection. The more data that is available for the common good, the better the digital solutions and analytical models will be. Insurance Europe believes that individuals should be able to allow access to their personal data to a much higher extent than is possible today. There should, for example, be practical solutions that would allow individuals to exercise control over their own data, with appropriate consideration given to the security of sensitive data. Individuals should be able to grant other parties access to the data generated by him or her, eg if a customer decides that an insurance undertaking may access his/her driving data, the vehicle manufacturer should grant access on reasonable terms. The insurance industry supports the strategy's aim that sector-specific legislation on data-sharing should only be introduced where there are identified market failures. The focus of the data strategy should be on strengthening the framework conditions for data collaboration and data partnerships. Insurance Europe supports the approach of the EU data strategy to create common European data spaces that build on existing EU legislation, eg the Open Data Directive and the General Data Protection Regulation (GDPR). It is crucial to have a data strategy at European level that allows the benefits of data usage to be maximised, while at the same time protecting and respecting users’ rights. Where possible and feasible, the data should therefore be presented in anonymised form. It is important that the development of common European data spaces creates a common understanding between industries with regard to data specification, update frequencies, governance, data quality, enforcement, etc. The alternative may result in a patchwork of unrelated, non-interoperable databases that offer no real benefit. It will also be important to establish a framework on how to exchange data between companies from a technical viewpoint, ensuring appropriate anonymisation of data to protect privacy. This would help to further encourage research and development, as well as the creation of anonymised data sources.
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Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

3 Jul 2020

Scope and legal instruments The proposed amendments of 2017/2358/EU are inappropriate. This Delegated Regulation applies to all insurance products not only to Insurance-based investment products (IBIPs). Amending product oversight and governance requirements for risk insurance (eg. home, health, motor) is unworkable in many instances. Equally the references to SFDR are to a Regulation that applies only to products with an investment purpose (e. g. IBIP, pension products). Including references in 2017/2358/EU extends the scope of SFDR definitions to also cover other products for which they are not applicable. It should be noted that the requirement to include sustainability considerations should only apply to products intended to be designed as sustainable. The current drafting does not make this distinction clear and implies that sustainability considerations should always be taken into account even where there are none. Definition of sustainability preferences The new definition of sustainability preferences based on the SFDR lacks the necessary flexibility to allow insurers to react to the needs of their customers. We understand the desire to reflect product categorisation under SFDR but the creation of additional categories of products through this initiative is unhelpful. Further consideration of the impact of this definition on product offering is necessary. Conflicts of interest IDD (and its delegated regulations) already establish appropriate criteria for determining different types of conflicts of interest. Any conflicts of interest that may arise from taking into account the sustainability objectives of customers would be captured by these criteria, with the result that they would be handled in the same way as any other conflicts of interest under the IDD. The detailed additions to the IDD regarding conflicts of interest are unnecessary. Target market Insurance undertakings are not required to consider sustainability factors in the product approval process of all insurance products. We are supportive of EIOPA’s original approach that makes clear that an Insurer should only take into account the sustainability profile of the product where this is relevant with regard to the respective target market, as this better reflects Insurers’ obligations under IDD. The legislator has specifically limited mandatory screening with regard to sustainability factors to large providers of products in the scope of the SFDR (Article 4 (3) and (4) SFDR). Provisions on level 2 should not create legal uncertainty in this regard. Implementation timeframe Insurance Europe welcomes the implementation period of 12 months starting with the entry into force of the Act. Insurers and intermediaries need sufficient time to implement the rules once they are finalised. More details on each of these issues including relevant amendment proposals as included in the attachment
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Response to Integration of sustainability risks and factors in relation to the business of insurance and reinsurance

3 Jul 2020

Please find attached the Insurance Europe detailed comments on the proposal. Our general comments can be found below. The European insurance industry supports the EC sustainability objectives and is fully committed to integrate sustainability into its business model. The sector already does this in many ways: eg prevention and adaptation, loss protection/compensation and long-term, sustainable financing of the economy. Solvency II (SII) currently does not represent an obstacle to the integration and measurement of sustainability risks. In fact, financially material sustainability risks can be taken into account in risk management, the ORSA and decision processes of the AMSB. In this context, the explicit references to sustainability proposed will help strengthen the integration of sustainability risks into SII in a consistent and efficient manner. The sector generally welcomes the EC amendments to integrate sustainability risks into insurers’ prudential framework and appreciates the explicit integration of sustainability risks in certain aspects of the regulation. However, we offer the following suggestions to improve the proposal. Art 1 The proposed definition (art 1, p 55e) of sustainability preferences is inconsistent and should be removed/amended to avoid misalignment between regulations and unintended effects. Clarification related to the Disclosure Regulation (SFDR) should be provided in the RTS of the SFDR, not in the sustainability preferences definition of the Insurance Distribution Directive (IDD) or SII. Art 260 The industry appreciates the EC amendment proposals for risk management areas: -With respect to art 260 (1)(a)(i), we suggest the following addition to clarify the amendment: “(…) due to internal or external factors, including sustainability risks where appropriate”. -Regarding paragraph 1(c)(vi) of art 260, given the inclusion of sustainability risks in the prudent person principle (Art 275a(2)), the industry deems this new paragraph redundant. Para 1(c)(i) already requires consideration of sustainability risks via the prudent person principle. -Regarding art 260 new para 1a, the following wording would offer improved clarity: “The insurance and reinsurance undertakings shall integrate sustainability risks where appropriate in their policies referred to in points (a) and (c) of para 1, and where relevant, in the policies on the other areas referred to in para 1.” Art 269 Regarding para 1a), the industry agrees that the consideration of material sustainability risks should be included in the ORSA. Nevertheless, insurers should be able to decide whether the ORSA is the right instrument to capture sustainability risks over time. Sustainability risks can materialise via existing risk categories and should therefore be considered at the same level as other risks. It is key that the analysis of sustainability risks is dependent on the company-specific strategy and risk assessment, based on financially material effects. Art 272 The proposed amendments regarding the tasks of the actuarial function are welcome. Art 275 The amendment on remuneration policy should not overlaps with existing requirements. Art 275a Art 275a should be improved for consistency & feasibility. As SII is designed for the policyholder’s protection, considerations on policyholder preferences should not be introduced in this article. To avoid an imbalance in regulatory requirements caused by highlighting only particular risks in an area under development, the following amendment is proposed to art 275a (1): “When identifying, measuring, monitoring, managing, controlling and reporting arising from investments, as referred to in the first sub-paragraph of Art 132(2) of Directive 2009/138/EC, insurance and reinsurance undertakings shall take into account all actual or potential financially material risks". This would help implement a more proportionate investment strategy in the interest of policyholders and shareholders.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · Covid-19 economic response, Solvency II, sustainable finance

Response to Climate Law

30 Apr 2020

As the impact of climate change on the daily lives of citizens and the broader eco-system is becoming increasingly clear, the European insurance industry is ready to continue contributing to the European Union’s political commitment to be climate neutral by 2050. The insurance industry can play a pivotal role in financing the transition to carbon-neutrality, resource-efficiency, and greater sustainability. Across Europe, insurers have already launched various initiatives in support of the United Nations’ Paris Agreement, for example. Moreover, leading insurers around the world have committed to implementing the recommendations of the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) through a partnership with the United Nations Environment Programme Finance Initiative (UNEP FI). The insurance industry is keenly aware of the impacts of a changing climate. As an industry, we are therefore also very conscious of the importance of prevention and adaptation measures. Adaptation enhancement is a key focus of the EC proposal for a European Climate Law, and Insurance Europe is highly supportive of the EC’s ambitions to step up efforts on climate-proofing, resilience building, prevention and preparedness. Given the growing importance of adaptation and the key role of the insurance sector as an investor and provider of protection, this document outlines Insurance Europe’s views on several aspects of the EC proposal. In line with the proposal for a European Climate Law (article 4), Insurance Europe believes that national and local authorities should enhance resilience by implementing effective prevention measures. Insurance Europe also supports the development of national adaptation plans and strategies, based on comprehensive risk management frameworks. The industry should be a key component of these national adaptation plans, frameworks and strategies and can continue to support the EU’s efforts to adapt to climate change. In order for the insurance industry to deliver fit-for-purpose solutions to the risks posed by climate change, it is important to ensure that the industry can benefit from a level-playing field and stable market for companies of all sizes. There is no one-size-fits-all solution at EU level: while all countries are affected by the changing climate, Member States each have different risk exposures resulting from regional environments, different levels of public awareness about potential risks, the extent of government intervention, liability regimes or adaptation practices. These factors result in a highly diverse insurance market for natural catastrophes across the EU. For instance, certain markets have a pool-solution in place where in others optional private market solutions are more common. Insurance Europe supports work of the Commission that would raise awareness of both the risks of a changing climate and of the appropriate insurance solutions. Data analysis presents insurers and authorities with the opportunity to generate a better understanding of climate risks and trends and to consequently mitigate the effects associated with these. Several national insurance associations in Europe are already working together with public authorities to share, systemise and analyse climate-related loss data. These types of partnerships are generally tailored to local market specificities, regulations and levels of awareness. The Commission should also pay due consideration to the intellectual property of insurers when considering data use. High-resolution datasets are intellectual property and form the basis of the insurance company's calculations. Broader partnerships or fora for dialogue involving all relevant institutional players and stakeholders, are needed to address, additionally, the underlying causes of risks, and to guarantee greater resilience to climate change as a result. This would allow players to get a holistic picture of risk and to take effective decisions.
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Response to Report on the application of the General Data Protection Regulation

28 Apr 2020

Insurance Europe welcomes the various opportunities offered by the European Commission (EC) to provide input to its report on the evaluation and review of the General Data Protection Regulation (GDPR). Insurance Europe has already responded to the EC stakeholder questionnaires and is now pleased to comment on the EC roadmap consultation on the report of the GDPR. Insurance Europe invites the EC to consider the views expressed in our contribution in COB-DAT-20-030.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

23 Apr 2020 · Situation of the European insurance sector in the Covid-19 pandemic

Response to Revision of Non-Financial Reporting Directive

27 Feb 2020

As Europe’s largest institutional investor (€10 200bn of assets under management), the insurance industry is in a unique position to help finance the transition to carbon-neutral, resource-efficient and more sustainable economies. The insurance industry is both an issuer and a preparer of non-financial information. As investors, insurers need to have access to reliable and comparable ESG data on investee companies - meaningful, consistent and comparable ESG reporting from companies helps investors to consider and account for sustainability impacts when making investment decisions. As preparers, we want to ensure that any requirements and standardisation are as effective and efficient as possible to avoid unnecessary costs and unintended consequences. Insurance Europe welcomes the European Commission’s revision of the Non-Financial Reporting Directive (NFRD). The industry recognises the need to update the directive to address the increased requirements for sustainability data and to achieve consistency with the scope of wider reform on sustainable reporting, including the regulation on sustainability disclosures in the financial services sector and the regulation on a classification system (taxonomy) of sustainable economic activities. In particular, there is strong support in the insurance industry for transparent ESG data/assessments directly reported by investee companies. This will help address the issues with data availability and quality which affect insurers’ compliance with their regulatory obligations in relation to ESG data The European insurance sector would like to stress the importance of taking into account the following factors when considering policy options: To the extent that ESG reporting is to satisfy the needs of stakeholders other than insurers and other investors, the NFRD should define who these stakeholders are and what their reporting needs which are different from those of insurers and other investors. The scope of investee companies who provide the information should be defined to satisfy insurers and other investors’ Environmental Social and Governance data needs. While strong requirements would be helpful for companies in determining what to report on, it is important that a certain level of flexibility remains to avoid rendering the NFRD obsolete in the near future. It is important that the revised NFRD remains principles based – which can be best achieved ifthe NFRD provides a general framework for reporting, and that more detailed requirements are set out as level 2 measures. The investee companies should be required to provide the data and the assessments (e.g. assessment against taxonomy) on a mandatory basis. The revised NFRD should be consistent with the requirements of the disclosures and taxonomy regulation to help investors comply with their data requirements. Therefore, the data and assessments provided must be aligned to the regulatory requirements set by the disclosure regulation and taxonomy regulation. Therefore, it is key that the Level 2 measures of the disclosure and taxonomy regulation are well known before the new mandatory reporting from the revised NFRD becomes applicable. Beyond what is required to comply with the disclosures and taxonomy regulations, no mandatory requirement should the benefits of introducing additional requirements outweigh the costs. The data and relevant assessments should be published in a standardised data format and available electronically in a way that facilitates access and minimises the cost for the investors and other users of the information.The materiality of disclosures should be taken into account to avoid costly processes which fail to deliver the required information at a proportionate cost. It is key to include this point in the revised text. Proportionality should be another strong focus point. The size and complexity of undertakings should be considered when developing guidance or requirements... (please find full response attached)
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

12 Feb 2020 · Insurance sector's main challenges and how to contribute to the green deal

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

12 Feb 2020 · Capital Markets Union, financial services

Response to Climate Law

5 Feb 2020

(Re)insurers are especially aware of and sensitive to the risks posed by a changing climate, both as an underwriter of risk and compensator of losses; and, as Europe’s largest institutional investor helping to finance the transition towards more sustainable economies. In fact, the European (re)insurance industry identified climate change as an emerging risk over two decades ago and has since campaigned for more action to be taken to help mitigate its impact. The (re)insurance industry therefore welcomes the Commission’s goal to become the world’s first climate-neutral continent by 2050 and is ready and willing to contribute to the European Green Deal. For more information on the (re)insurance industry’s ambitions for a greener, more sustainable Europe please consult the following document: https://www.insuranceeurope.eu/sites/default/files/attachments/Ambitions%20for%20Europe%20-%20Create%20a%20greener%2C%20more%20sustainable%20Europe.pdf
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

9 Jan 2020 · Packaged retail and insurance-based investment, Solvency II

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

7 Jan 2020 · Insurance industry, Solvency II Review

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

13 Jun 2019 · EU and international developments, impact on reinsurance industry

Response to Evaluation of the Distance Marketing of Financial Services Directive

19 Dec 2018

Insurance Europe welcomes the European Commission’s (EC) initiative to evaluate the Distance Marketing of Consumer Financial Services Directive (DMD), and supports the approach taken by the EC in the roadmap. In particular, we agree with the EC that the DMD should be evaluated to assess whether the Directive responds to the evolution of the digital market for financial services. Distance marketing of consumer financial services has evolved since the adoption of the DMD in 2002. This shift has been influenced –among other reasons - to the rapidly-evolving digital environment in which we live, the increasing access to the internet, and consumers’ growing demand to purchase products online. Given these circumstances, it seems sensible to assess whether the DMD remains fit to respond to market developments. Importantly, the roadmap highlights the need to evaluate the DMD in view of the latest legislative developments in the framework for retail financial services and products. In this regard, Insurance Europe recommends that the EC takes the opportunity to address any information overlaps and duplications between the DMD and other pieces of financial legislation (including the Insurance Distribution Directive, the Regulation on Packaged Retail and Insurance-based Investment Products and the Solvency II Directive) and cross-sectoral legislation (such as the ecommerce Directive and the General Data Protection Regulation) that risk overloading and confusing consumers. It is crucial that the EC addresses this problem and takes a holistic approach in any upcoming legislative reviews. Furthermore, the EC should also take the opportunity to evaluate the digital friendliness of financial legislation. To address the above concerns, Insurance Europe calls on the EC to consider in its DMD evaluation the REFIT Platform Opinion (Financial Services: X.21.a) on Insurance Europe’s submission on (i) information overload and duplication, and (ii) paper requirements (“unfriendly digital rules”). Insurance Europe welcomes the upcoming public consultation planned for early 2019 and will take the opportunity to submit input. Moreover, we stand ready to provide feedback through the targeted consultation and look forward to receiving further details on the planned content and timeline.
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Response to Amendments to the implementing rules on solvency applicable to insurers

6 Dec 2018

Insurance Europe welcomes the opportunity to provide comments to the EC draft proposals for changes to the Solvency II Delegated Regulation. Please find enclosed the Insurance Europe position paper, which includes our general and specific comments on the EC draft proposals for changes to the Solvency II Delegated Regulation. General comments Insurance Europe welcomes the EC proposals aimed at introducing a number of simplifications and a more proportional application of the framework in a number of areas. However, Insurance Europe is concerned that the 2018 review lacks ambition in key areas such as the recalibration of long-term equity and the review of the risk margin – both of which would have a significant and direct impact on long-term investments and would in fact support the EC in achieving the objectives of its CMU project. With respect to the recalibration of long-term equity investments, Insurance Europe appreciates recognition by the European Commission that action is needed. However, Insurance Europe believes that the technical proposal will not work in practice for any undertaking because of the way in which the criteria are defined. Insurance Europe calls on the EC to take swift action to amend its proposal in a way that makes it workable in practice. With respect to the review of the risk margin cost of capital, Insurance Europe reiterates its strong concerns on the current calibration of the cost of capital and more broadly the design of the risk margin. There is extensive evidence that the 6% cost of capital is too high and the industry believes that ignoring such evidence and preserving the status quo is in fact a missed opportunity not only to correct the flaws of the framework, but also to remove the current barriers to provision of long-term business and investment by the industry. Furthermore, the current EC proposals on LAC DT contradict key elements of Solvency II, such as the going concern principle and supervisory judgement and dialogue. Insurance Europe calls for adjustments to the draft text to remove arbitrary limits. Insurance Europe welcomes the EC’s intention to fully review the volatility adjustment as part of the review of the Directive in 2020. However, the current year has provided significant additional evidence of the improper functioning of the volatility adjustment and it is disappointed that the EC has not proposed any short-term improvements to allow an improved, although not perfect, functioning of the national market component. Insurance Europe calls for clarifications to be made in the Delegated Regulation regarding the activation criteria governing the national market component, which are in line with the Directive. With respect to the application date of the proposed changes, Insurance Europe calls for the application date of the new LAC DT proposals to be 1 January 2020. This is an area that will not only require internal adaptation of companies’ systems to the prescriptive EC requirements, but also an area expected to largely have a negative capital impact. The EC itself acknowledges that the potential increase in the capital requirement is the key reason behind the later application date for the credit and suretyship segment – so Insurance Europe believes that this is a very valid argument for LAC DT as well.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

27 Sept 2018 · Solvency II reviews - sustainable finance - financial reporting (IFRS 17) - ESAs review

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Nathalie De Basaldua Lemarchand (Cabinet of Vice-President Jyrki Katainen)

3 Sept 2018 · EFSI/InvestEU and Solvency II

Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on disclosures relating to sustainable investments and sustainability risks. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments on the EC proposal.
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Response to Institutional investors' and asset managers' duties regarding sustainability

23 Aug 2018

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on the establishment of a framework to facilitate sustainable investment. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments on the EC proposal.
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Response to Multiannual Financial Framework-Draft legislative proposal on the InvestEU Programme and EFSI evaluation SWD

8 Aug 2018

Insurance Europe welcomes the opportunity to comment on the European Commission (EC) proposal for a Regulation establishing the InvestEU Programme. The insurance industry represents the largest European institutional investor, with more than €10tn of assets under management. Insurers invest most of their assets with a long-term perspective, and in their investment strategies they target portfolio diversification and attractive returns, to the benefit of their policyholders. The insurance industry welcomes the InvestEU Programme, but will only be able to act at its full investment potential if the EC addresses both the scarce availability of suitable assets and the barriers to long-term investment created by Solvency II. Please find enclosed the Insurance Europe position paper, which includes our detailed comments on the European Commission (EC) proposal for a Regulation establishing the InvestEU Programme.
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Response to REFIT review of the Motor Insurance Directive

24 Jul 2018

Dear Sir/Madam Please find attached Insurance Europe's preliminary comments on the EC proposal to revise the Motor Insurance Directive. Thomas Gelin Policy Advisor
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

11 Jul 2018 · Future of the EU priorities of the Juncker Commission

Response to Targeted revision of EU consumer law directives

21 Jun 2018

Please find attached Insurance Europe's key messages and concerns on the proposal for representative actions.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

General comments Insurance Europe welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products (IBIPs). Insurance Europe agrees that the existence of any customer ESG preferences would be a useful consideration to include during the advisory process. However, it would like to point out some practical elements which need to be considered to ensure that the ultimate benefit is afforded to the customer. - Transitional period Insurance Europe appreciates the introduction of a transitional period in the draft Regulation, which provides for a date of application that is 18 months after its entry into force. It is crucial to allow insurance undertakings and intermediaries sufficient time to adapt to the new requirements so that they can be applied in an efficient and effective manner. This is of particular relevance in light of the fact that some member states have already implemented IDD. Any transitional period should therefore only commence once the overall taxonomy, or ESG classification system, has been finalised. Alternatively, such changes could be introduced within the context of the IDD review, by which time the relevant taxonomy will have been established. - Choice of wording Insurance Europe notes that the Commission has used the same definition of “ESG preferences” as in the proposed amendments to the MiFID II Delegated Regulation on organisational requirements (Commission Delegated Regulation (EU) 2017/565). However, the MiFID II amendments use a different wording, which acknowledges that customers may or may not have ESG preferences. Recital 8 of the proposed amendments to the IDD Delegated Regulation on IBIPs acknowledges that “the final recommendations to the customer should reflect both the financial and, where relevant, ESG preferences of that customer”. The wording of the proposed Article 1, however, seems to assume that all customers have ESG preferences. In this particular case, it would be more appropriate to use similar wording as in the MIFID II amended Delegated Regulation. Insurance Europe would therefore suggest introducing the following clarifications to the text of the proposed Article 1: - Article 1(2): • Point (a) of Article 9 para 2 should be redrafted to recognise that the customer may or may not have ESG preferences: “(a) it meets the customer’s or potential customer’s investment objectives, including that person’s risk tolerance and his or her ESG preferences, if any;” The above wording corresponds to the wording used in the amended MiFID II Delegated Regulation. The following amendment to the text could alternatively help to resolve this issue: “(a) it meets the customer’s or potential customer’s investment objectives, including that person’s risk tolerance and any ESG preferences;” • The fact that a customer may or may not have ESG preferences seems to be already recognised in para 4 of Article 9, which adds “where relevant” in the text. - Article 1(3): • Point (i) of Article 14(1)(b) should similarly be redrafted to recognise the element of choice as to whether or not a customer has any ESG preferences: “(i) the customer's investment objectives, including that person's risk tolerance and any ESG preferences;”
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

24 May 2018 · Speech at Insurance Europe Conference

Response to Revised calibrations for securitisation investments by insurance and reinsurance undertakings under Solvency II

15 May 2018

Insurance Europe welcomes the opportunity to provide comments on the European Commission consultation on revised Solvency II calibrations for STS securitisation investments. Please find enclosed the Insurance Europe position paper, which includes our general and specific comments on the EC proposal to amend Solvency II capital requirements for STS securitisations.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

19 Apr 2018 · Solvency II review

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

18 Apr 2018 · exchange views with you on the use of and access to data generated by vehicles, in the context of connected and automated cars.

Response to Fitness check on public reporting by companies

8 Mar 2018

Insurance Europe welcomes the opportunity to provide feedback to the Commission’s roadmap on assessment of EU’s public reporting requirements. As an industry providing risk mitigation and undertaking long-term investment activities, the insurance industry plays a key social function that can be helped or hindered by public reporting. With 10 trillion euros of investments, the European insurance industry has a major interest in efficient and meaningful public reporting as Europe’s largest institutional investor. Finally, as preparers with a long-term business model that does not easily fit into traditional accounting frameworks, the insurance industry has a very strong interest in reporting frameworks that are practical and meaningful across all European markets. As stressed in its response to the 2015 EC call for evidence, Insurance Europe believes that a number of elements of the reporting requirements covering the insurance sector deserve a careful refinement by the EC, in order to meet their goals of effectiveness, relevance, coherence, and efficiency. In their current state, reporting requirements in the financial sector are more costly and burdensome than necessary. This is, to a large extent, due to duplicative and overlapping reporting requirements, but also due to insufficient standardisation as well as a lack of clarity on what needs to be reported (e.g. lack of harmonised financial data definitions). Pressure to expand the current non-financial reporting further can exacerbate this if not done carefully taking into account various existing and other under development requirements. Insurance Europe therefore welcomes the Commission’s initiatives to carry out a Fitness Check on public reporting and also its parallel, and currently in progress, Fitness Check on supervisory reporting. However, the insurance industry is currently going through a period of enormous change with some of the reporting requirements newly introduced (e.g. Solvency II), some in the process of assessment/endorsement/interpretation/implementation (IFRS 17 Insurance Contracts) and others to be implemented (IFRS 9 Financial Instruments). This all involves a very high commitment of system and human resources for insurance companies. Therefore, while we support the initiative as such, the timing - with only 12 weeks starting already in March 2018 - is very problematic for the industry and there is a significant risk that there will be insufficient resources and/or time for many companies to provide good responses for such an important initiative. There is a significant risk that insurance companies will not be able to allocate the necessary resources to the consultation to thoroughly assess of the EU directives and delegated acts within the envisaged scope of the Fitness Check. Insurance Europe believes, considering the extent and scope of this Fitness Check, that a delay and an extension of the consultation period should be considered.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

23 Feb 2018 · PEPP - IDD - PRIIPS

Response to Amendment to Directive (EU) 2016/97 on insurance distribution.

15 Feb 2018

Insurance Europe welcomes the European Commission proposal to delay the date of application of Member States' transposition measures of the Insurance Distribution Directive (IDD). It is crucial that the European insurance industry has sufficient time to implement the required changes from the point at which regulatory certainty is established. Given that the Level 2 delegated acts (DAs) were only published in the Official Journal of the EU on 20 December for a directive that enters into force on 23 February, industry considers this timeline too tight to give firms a realistic timeframe to properly design and test the necessary changes. An extended application date will allow the sector to better prepare for the correct implementation of the IDD, which will also benefit consumers. A swift endorsement of the proposal delaying the application date, is now imperative. Although we understand that is it now impossible for all procedural steps to be carried out in time to ensure the delay enters into force before the current application date of IDD, any delay in formal adoption of the amending Directive should be kept to a minimum. It is also crucial that a mechanism such as the current proposal to retroactively apply the delay is included in the final text, so insurers can be certain of which rules will apply. The European insurance industry strongly calls on the European institutions to take the necessary action to avoid this happening again in the future, as the current situation with IDD has led to legal uncertainty and has also created the risk of potential litigation action against companies. Insurance Europe also wishes to raise the more general concern of the too-tight timelines allowed for the implementation process of legislative initiatives under the present Lamfalussy process. We call on the Commission to give serious consideration to the introduction of separate transposition and application dates in its legislative proposals, so as to ensure that there is a minimum period of one year for implementation by all concerned parties following the conclusion of the Level 1 and Level 2 texts.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

Insurance Europe appreciates this opportunity to provide feedback to the European Commission at an early stage in the review of the European supervisory authorities (ESAs) via the “Have your say” platform. Insurance Europe believes that an efficient, effective and credible system of financial supervision is essential at EU level. The stability of the supervisory framework is crucial to achieving this. Insurance Europe has prepared additional comments on governance and the new and redefined powers in the ESAs review in its feedback on the proposal for a regulation COM(2017)536/948972. The comments provided below refer not only to the changes proposed to the Solvency II Directive but also to Articles 21 and 21a of that proposal for a regulation amending the current EIOPA Regulation.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

Insurance Europe appreciates this opportunity to provide feedback to the European Commission at an early stage in the review of the European supervisory authorities (ESAs) via the “Have your say” platform. Insurance Europe welcomes the EC’s recognition of the need for stability and sectoral expertise and to maintain the European Insurance and Occupational Pensions Authority (EIOPA) as a stand-alone authority, responsible for both prudential and conduct of business supervision. Insurance Europe has long called for governance and oversight improvements to the ESAs. The current governance structure of the ESAs does not provide for adequate checks and balances, and the proposed changes exacerbate this in parts, especially where the powers and tasks of the authorities are increased without adequate control mechanisms. Insurance Europe recommends including “acting in the interest of the European public good” as an explicit part of the ESAs’ mandate because this, together with other governance improvements, can help ensure that the ESAs have the necessary independence but also take a proportional and balanced approach to their supervisory activities, taking into account, for example, unintended consequences for citizens, the economy and the financial sector. In terms of governance improvements, Insurance Europe supports the proposal for the European Parliament and Council to appoint three senior executives to EIOPA Board as long as they are suitably senior, experienced and qualified. However, the extent to which the proposals exclude the Board of Supervisors (BoS), which brings much-needed practical and local knowledge and experience to discussions and decisions, is concerning. Such an exclusion is only necessary and justified where there is a significant risk of conflict of interest. There is also a need for higher transparency in relation to agendas and supporting documents in the BoS, the Executive Board and the Joint Committee. Effective governance and external oversight mechanisms are essential to achieving a credible supervisory landscape. Both the European Parliament and the EC should play a role in ensuring that external oversight of the ESAs’ activities is in place at all times. Insurance Europe remains unconvinced that EIOPA needs any significant changes to its powers to be able to fulfil its mandate, although it recognises that there is a need for clarification of certain existing powers and to ensure EIOPA has access to information from national competent authorities (NCAs). However, care must be taken not to undermine the principles of subsidiarity and proportionality. With a view to ensuring adequate and proportionate budgets to enable the ESAs to perform their tasks, it is essential that the process to establish the ESAs’ budget needs and their budgets is overseen effectively by the European institutions, and that the process is sufficiently transparent to make this possible.
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Meeting with Alina-Stefania Ujupan (Cabinet of Commissioner Mariya Gabriel)

30 Nov 2017 · Connected and automated cars

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

10 Oct 2017 · Sustainable Finance and Solvency II

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

19 Sept 2017 · Solvency II

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

16 Aug 2017

Please find attached the Insurance Europe feedback on the DA on conduct of business rules for the distribution of IBIPs.
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Response to DA on product oversight and governance requirements for insurance undertakings and insurance distributors

16 Aug 2017

Please find attached the Insurance Europe feedback on the DA on product oversight and governance.
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Response to REFIT review of the Motor Insurance Directive

11 Aug 2017

Dear Sir/Madam Please find attached the full feedback from Insurance Europe and the Council of Bureaux. Insurance Europe is the European insurance and reinsurance federation. Through its 35 member bodies — the national insurance associations — Insurance Europe represents all types of insurance and reinsurance undertakings, eg pan-European companies, monoliners, mutuals and SMEs. The Council of Bureaux is the managing organisation of the Green Card system, the protection mechanism for victims of cross-border road traffic accidents created under the aegis of the United Nations. The Council of Bureaux also provides secretarial services for the bodies created by the Motor Insurance Directive (Compensation Bodies, Guarantee Funds and Information Centres). We remain available should you have any query on this feedback. Yours faithfully Thomas Gelin Policy Advisor (Insurance Europe)
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Response to EMIR Amendment

18 Jul 2017

Insurance Europe welcomes the opportunity to share its views regarding the European Commission’s proposal for amendments to the EMIR regulation. The insurance industry is the largest institutional investors in Europe with total assets of approximately €9.9tn. Derivatives are key for insurers in their risk and efficient portfolio management. The insurance industry continues to support the underlying objectives of EMIR, including on collateralisation and reporting obligations. Insurance Europe welcomes the recent EC proposal amending EMIR and in particular the following changes: - Removing the requirement for dual-side reporting of exchange-traded derivatives. Insurance Europe supports the EC proposal for CCPs to be solely responsible for reporting the details of such transactions (new paragraph 1a in Article 9). - Clarifying that the obligation to centrally clear may be temporarily suspended by ESMA, thus ensuring that insurers are not exposed to liability in cases of CCP failure or exit from providing clearing services for particular contract types (new Article 6b). - Attempting to address the access issues which small- and medium-size insurers face when trying to secure arrangements with clearing members for the provision of central clearing services (new paragraph 3a in Article 4 (3)). However, Insurance Europe believes that several concerns raised by the insurance industry in the past with respect to EMIR are still outstanding and should be addressed as part of this review. These include: - In the area of intragroup transactions, the burdensome procedures around exempting OTC intragroup transactions from collateralisation requirements should be simplified. - In the area of reporting, single-side reporting should be introduced for all centrally cleared transactions, and not only for exchange-traded derivatives, as currently proposed. In addition, the industry remains concerned by the practical application of EMIR, which requires insurers to post cash when centrally clearing. As highlighted in the past, the industry has significant concerns over the potentially high need for cash to cover variation/initial margin needs. While EMIR recognises the cash challenge faced by pension scheme arrangement (PSA), it fails to recognise that the same challenge applies to all insurers with long-term business. Insurance Europe welcomes the EC’s decision to delay variation margin posting obligations on PSAs. Furthermore, it welcomes the proposed mandate for the European Supervisory Authorities (ESAs) and the ESRB to investigate and assess whether further measures are necessary to facilitate clearing solutions for PSAs. Insurance Europe looks forward to contributing to this work, and believes that any investigations should also cover the concerns of the insurance industry and any solutions found should also be considered for the insurance industry.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

12 Jun 2017 · Information exchange

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

7 Feb 2017 · Fintech; PRIPS

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

20 Jan 2017 · CMU, Solvency II, Private Pensions, PRIIPs

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen)

16 Jan 2017 · CMU EFSI

Meeting with Valdis Dombrovskis (Vice-President)

27 Oct 2016 · Insurance issues, Solvency II, Personal pensions, PRIIPS

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

27 Sept 2016 · conduct of business, Solvency II review and the Capital Markets Union, international standards and pensions.

Meeting with Bodo Lehmann (Digital Economy), Michael Hager (Digital Economy)

15 Jun 2016 · DSM

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

14 Jun 2016 · Packaged retail and insurance-based investment products

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

29 Apr 2016 · CMU

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

10 Mar 2016 · Solvency II, Better Regulation, CMU, Green Paper on Retail Financial Services

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

23 Feb 2016 · Cross-border provision of insurance in the single market

Meeting with Jonathan Hill (Commissioner) and Swiss Re Ltd. and Lloyd’s Insurance Company SA

15 Feb 2016 · Market access in third countries for EU reinsurers; EU/US negotiation on a covered agreement for insurance and reinsurance; international issues (IAIS)

Meeting with Jonathan Hill (Commissioner)

15 Feb 2016 · CMU; Solvency II, PRIIPS, IDD

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen)

14 Dec 2015 · Investment initiative

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

19 Nov 2015 · Retail financial services green paper

Meeting with Eric Mamer (Digital Economy)

16 Nov 2015 · DSM

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

21 Oct 2015 · GDPR

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

12 Oct 2015 · Insurance - connected vehicles

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

12 Oct 2015 · motor insurance: current trends and technological developments

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

12 Oct 2015 · Promotion of the European Union’s key initiatives for the COP21

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

27 Aug 2015 · Latest on insurance; infrastructure definition; securitisation; CMU; 29th pension regime; Solcency II

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

22 May 2015 · Investment plan, Solvency II (infrastructure, ELTIF), Equivalence, insurance in general

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

14 Apr 2015 · Financial Policy

Meeting with Jyrki Katainen (Vice-President) and

20 Mar 2015 · Investment Initiative

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

3 Mar 2015 · Financial policy

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

16 Jan 2015 · Solvency II

Meeting with Jonathan Hill (Commissioner)

17 Dec 2014 · Insurers' major role as institutional investors in the European economy