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Insurance Pension Denmark

IPD

Mission of the IPD: The IPD represents the interests of the Danish non-life and life insurnace companies and industry-wide pension funds.

Lobbying Activity

Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall) and Finanssiala ry - Finance Finland and

15 Jan 2026 · The link between insurance and the environment portfolio, resilience, simplification, the Single Market

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and Confederation of Danish Industry and

8 Dec 2025 · Address to the cleantech MFF roundtable: An EU Budget for a Stronger, Cleaner and More Sovereign Europe – Recommendations from Danish Investors, Business Community & Civil Society

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

17 Nov 2025 · Digital topics affecting the insurance and pension sector

Response to Digital package – digital omnibus

13 Oct 2025

AI Act - Stop-the-clock: The AI Acts high-risk rules are complex and will impact a wide range of businesses and public authorities in the EU. Standardization experts have already spent over three years translating the regulations requirements into practical implementationsand they are not finished. The current deadline, August 2026, coincides with the rules coming into force, leaving organizations no time to leverage the experts work. As a result, organizations will be forced to replicate this work in less than half the time, creating significant burdens that the simplification agenda must address. Recommendation: Stop the clock and postpone deadlines to allow key guidelines and standards to be finalized before the high-risk AI rules take effect. AI Act: Clear distinction between AI and traditional statistics: We ask for explicit clarification that traditional statistical methods, including generalised linear models (GLMs), that have been used in a consolidated manner for many years, are outside the scope of the AI Act as they should not and do not fall under the definition of an AI system. Such clarification would prevent ambiguity, inconsistent interpretation, and unnecessary burdens on companies and supervisors regarding existing statistical analysis and modeling. It would also help focus the definition of AI on its most salient characteristic. Streamline DORA-reporting: We recommend streamlining DORA reporting, with a focus on: - Reducing the administrative burden of cyber incident reporting. - Improving data processing practices to make information registers more efficient and effective. - Simplifying the reporting process for information registers. - Aligning DORA guidelines and reporting requirements. - Establishing a centralized repository of subcontractor information at the European level. For further details, we refer to the consultation response from Insurance Europe. Overlapping enforcement: When digital regulations (e.g. GDPR and AI Act) have different enforcement mechanisms and supervisory authorities, companies could face investigations under both laws for the same issue, with authorities interpreting overlapping rules differently. This highlights the need for coordination to reduce the risk of inconsistent enforcement and overlapping demands. AI-act and data (GDPR): The AI Act and GDPR intersect, as AI Act allows data use for trustworthy AI while GDPR may restrict it. Four areas are particularly important: 1 Sensitive personal data: Under the GDPR, the use of sensitive data is strictly limited. The AI Act allows such data to test and correct bias in high-risk AI models, but no similar allowance exists for low-risk models. The challenge: organizations may need sensitive data to ensure AI fairness, but using it for low-risk AI testing could conflict with GDPR rules. 2 Data minimization vs data quality: The GDPR requires minimizing personal data collection and processing, while the AI Act emphasizes that AI systems need large, diverse, and representative datasets to perform accurately and fairly. These goals conflict: limiting data protects privacy but may reduce AI quality and fairness. To ensure trustworthy AI, further clarification or specific provisions will be needed - especially regarding the use of data for training and testing. 3 Purpose limitation: GDPR states that personal data must only be used for the specific purpose for which it was originally collected AI systems often rely on reusing data to test, retrain or improve models over time, creating tension between the flexibility needed for trustworthy AI and GDPRs purpose limitations. 4 Automated decision-making: GDPR grants rights in relation to automated decision-making, such as requiring transparency and offering human review. The AI Act introduces requirements for human oversight and transparency in high-risk AI systems. These frameworks should be aligned so organizations can meet both sets of obligations consistently.
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Response to General revision of the General Block Exemption Regulation

6 Oct 2025

F&P has received the special committee consultation as an information-al note regarding the European Commissions call for evidence concern-ing the revision of the General Block Exemption Regulation (GBER), No. 733/2013 of 22 July 2013. The regulation sets out the conditions under which granting authorities may award state aid without prior notification to and approval by the Commission. F&P has the following general observations: The main purpose of the consultation and the request for feedback is to gather experiences and information from national, regional, and local authorities, stakeholders, and citizens, in order to enable the Commis-sion to assess how the GBER can be revised, including with a view to simplification. This time, the Danish agenda differs from the previous revision of the regulation. From a Danish perspective, F&P envisions that block exemp-tions could be expanded to include areas such as climate adaptation, sustainability (e.g., sustainability agreements), defense (unless fully exempt from competition rules), cybersecurity, and consumer protection (with the aim of raising the level without harming consumers, but ra-ther ensuring that the level of consumer protection does not decline). F&P believes that block exemptions in the aforementioned areas could be value-creating in the long term and ensure that the rules are adapted to the reality we live in today. Should further elaboration be needed, we are of course available.
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Meeting with Yann Germaine (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

27 Mar 2025 · Exchange of views on insurance guarantee schemes

Meeting with Maria Luís Albuquerque (Commissioner) and

25 Mar 2025 · Discussion on relevant developments

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

30 Jan 2025 · Sustainable Finance Disclosure Regulation