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Muenchener Rueckversicherungs-Gesellschaft Aktiengesellschaft in Muenchen

Munich Re

Munich Re adopts a prospective, prudent and responsible approach to risk management.

Lobbying Activity

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Assicurazioni Generali S.p.A and Allianz SE

14 Oct 2025 · Solvency II

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

7 May 2025 · Risk Margin

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

12 Dec 2023 · EU Competitiveness and administrative burden

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

10 Jul 2023 · Insurance Regulation: Solvency II

Response to European Sustainability Reporting Standards

7 Jul 2023

Thank you for the opportunity to take part in the consultation on Set 1 of the European Sustainability Reporting Standards (ESRS). For Munich Re, as a global reinsurance company, the subject of sustainability is of high strategic relevance. Against this background, we are interested in high-quality, standardised reporting on sustainability information. This holds true both as a recipient of sustainability information in our role as global investor and as a preparer of sustainability reports, in which we are directly affected by the regulations. Whilst we appreciate the standardisation of sustainability information, we are concerned that the considerable additional implementation and ongoing costs of the European sustainability reporting - even taking into account the aspects outlined below - imposes an undue burden to European companies that are in global competition. We therefore advocate for significant reductions in proposed European sustainability reporting requirements and convergence to ISSB Standards in particular regarding financial materiality. With the publication of sector-agnostic standards, the EU has published a comprehensive set of reporting requirements covering a wide range of sustainability topics. Overall, we would have appreciated greater harmonisation between European Standards and ISSB Standards (e.g., regarding the definition of financial materiality). Particularly for our globally oriented business, the idea of a global baseline is an important prerequisite for uniform and standardised sustainability information and would make it easier for the target audience to derive decision-relevant information from the wealth of information. There are still outstanding questions regarding the interoperability of both standards, especially as regards mutual recognition. We support the chosen path of putting the entire focus on materiality instead of plenty of mandatory data points. This makes it possible to derive the relevance of information in a company-specific and business model-specific way. In the same way, corresponding requirements of the SFDR should be amended (e.g. on reporting a qualified zero or assuming zero in cases where companies do not report SFDR-relevant data points). We would nevertheless have appreciated a significant reduction in data points from the publication of Set 1. From our point of view, the set of regulations is still far too complex and detailed overall. We also think the definition of materiality is too broad overall, especially for insurance companies with widely diversified investment and insurance portfolios, particularly if the resulting information subsequently becomes part of our annual report and considerable demands arises for data compilation, information presentation and auditing. Here too, the interests of the target audience of sustainability reporting must be included in order to be able to focus more strongly on information that is relevant for the reader. The definition of value chains for insurance companies continues to be unclear for the purposes of implementation. The industry is working on proposals as to how the value chain can be analysed in a principle-based way. Here we would like to see more guidance, as ultimately the scope of reporting mainly depends on how the value chain is defined. Against this background, we propose that quantitative information on the value chain should only be reported once sector-specific standards for insurance companies have been developed. (...)
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Meeting with Markus Ferber (Member of the European Parliament, Rapporteur) and Deutsche Aktuarvereinigung e.V.

3 Mar 2022 · Insurance Regulation: Solvency II

Meeting with Johannes Hahn (Commissioner)

26 Jul 2021 · Exchange of views on the prospects for European economic recovery

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

9 Mar 2021 · Basel III

Meeting with Günther Oettinger (Commissioner)

9 Sept 2019 · MFF

Meeting with Günther Oettinger (Commissioner)

15 Feb 2019 · Future of Europe

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen), Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen) and

25 Mar 2015 · Investment plan and EU economic outlook