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Svensk Försäkring

Svensk Försäkring är försäkringsföretagens och tjänstepensionsföretagens branschorganisation.

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 Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Savings and Investments Union – exchange with Swedish institutional investors and intermediaries

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Insurance Europe

1 Apr 2025 · AI in Financial Services

Meeting with Arba Kokalari (Member of the European Parliament)

27 Mar 2025 · Savings and Investments Union

Response to Savings and Investments Union

7 Mar 2025

Insurance Sweden welcomes the possibility to provide feedback on the Savings and Investment Union (SIU). As a member of Insurance Europe, we share the views expressed in their response to the Call for Evidence. In this response we wish to highlight and elaborate further on some experiences from the Swedish insurance market. We believe that there are important lessons to be learned for the SIU. As highlighted in Mario Draghi's report on EU competitiveness, Sweden benefits from well-functioning financial markets. The substantial investments made by Swedish insurance companies and IORPs have contributed to this strength. These investments originate primarily from occupational pensions and Private Endowment Insurance (PEI). PEI benefits from a simplified tax treatment through a yield tax, a treatment that is similar to that of the national savings account (ISK). This simplified taxation is most probably an important explanation to why these two types of savings products are popular among individuals in Sweden. Given the differences between the two savings products, they provide the individual with the possibility to choose the one that best suits one´s savings preferences or a mix of the two. One difference between ISK and PEI is that the latter allows for savings not only in investment funds and equities but also in traditional life insurance with guarantees. Another difference is that SME:s are allowed to save in PEI, contrary to ISK. PEI also streamlines the ownership of foreign securities, as the insurance company handles the reclaiming of withholding tax on behalf of investors. Finally, PEI offers flexibility in the timing of payouts, including the option of lifelong monthly payments, which makes PEI a suitable savings product for retirement. In Sweden, savings in PEI are not subject to geographical limitations on investment choices. The absence of such limitations could have contributed to the interest among Swedish households in this insurance product. A substantial portion of the capital allocated to PEI as well as occupational pension schemes is invested within the EU, predominantly in equities and equity funds. Given these features, we argue that Swedish PEI align with a framework of a standardized EU savings product, should such a product be incorporated into the SIU. See the attached document for further details on PEI in Sweden. Another reason of the success of PEI is the low fees for Swedish insurance products, as been pointed out by EIOPA (Cost and past performance report, Dec 2023). The retail investment strategy (RIS) should be designed so that it promotes retail investors participation, and not the opposite as would be the effect of current proposals of RIS. The proposals on Value for Money, inducements and disclosures etc would lead to higher fees and reduce the demand for PEI in Sweden. RIS also shows the need for a better process for new regulation, including thorough impact analysis. Through their investments, Swedish insurance companies and IORPs have contributed to favourable business conditions in Sweden. Sound and reliable regulation is vital for healthy EU industries. However, the regulatory environment must allow European businesses to enhance their competitiveness and their ability to contribute to EUs objectives of sustainable, innovative and inclusive growth. This is key for the success of the SIU. Furthermore, the regulation for insurance companies and IORPs should be simplified and the administrative burden should be reduced. This would increase the investment opportunities for these companies, thereby, supporting the SIUs goals of strengthening the competitiveness of EU and facilitating the green and digital transition.
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Meeting with Arba Kokalari (Member of the European Parliament)

28 Feb 2025 · Savings and Investments Union

Meeting with Adnan Dibrani (Member of the European Parliament)

26 Sept 2024 · Försäkringsfrågor

Meeting with Arba Kokalari (Member of the European Parliament)

26 Sept 2024 · Insurance and banking

Meeting with Tomas Tobé (Member of the European Parliament)

27 Mar 2024 · Insurance Policy

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

30 Sept 2022 · Financial services contracts concluded at a distance

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

13 Jan 2022

Insurance Sweden welcome this opportunity to comment on the proposed Insurance Recovery and Resolution Directive (IRRD). As a member of Insurance Europe, we share the views expressed in their response on the European Commission’s (EC) proposal of IRRD. In the attached response we highlight and elaborate a bit further on some of the issues in IRRD from a Swedish perspective and express our strong objection of introducing EC’s proposal of IRRD. This is a too burdensome, extensive, and disproportionate framework for recovery and resolution of (re)insurance companies in Sweden and the rest of EU, with no benefits for the financial stability in Sweden or for Swedish policyholders. In our attached response we also express our strong objection of having requirement of market coverage for recovery and resolution planning.
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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

As a member of Insurance Europe, Insurance Sweden overall share the views expressed in its response to the European Commission’s (EC) proposed amendents in the current review of the Solvency II Directive. However, in the attached document we wish to highlight and elaborate further on the proposal to widen the corridor for the symmetric adjustment to the equity risk charge by amending Article 106 (3). We would also like to clarify Insurance Sweden’s strong position against such a change. In addition, we support Insurance Europe’s view that the symmetric adjustment should be optional to apply. In the attached document we also would like to express our strong objection against EC’s proposal of how to divide SFCR into two parts by amendments to Articles 51 and 256, which we believe will only increase the burden of reporting without any tangible benefits.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Insurance Sweden is the industry organisation for insurance undertakings in Sweden. We welcome this opportunity to comment on the draft delegated act on technical screening criteria under the Taxonomy Regulation. Our comments focus on three activities: • Activity 10 Financial and insurance activities – We support the consultation response by Insurance Europe and urge the European Commissions to adjust the screening criteria accordingly. • Activity 7.7 Acquisition and ownership of buildings – We regret that the technical screening criteria for activity 7.7. Acquisition and ownership of buildings have been changed compared to the final TEG proposal. The new screening criteria do not represent an objective and uniform measure across the EU. The current proposal for buildings built before 31 December 2020 is based on the Energy Performance Certificate (EPC). Specifically, a building needs to have at least EPC class A to qualify as taxonomy compliant. Unfortunately, the performance rating of the EPC is not harmonized across the EU. Instead, it is up to each Member States to decide on the performance rating of the representation. Since the energy performance rating is set very high in Sweden, almost no buildings qualify for the EPC class A – even though their energy performance is very high in an EU context. In fact, the threshold in the Swedish Building Code for EPC class A is set to 50% better than the requirements for new buildings (NZEB). Meanwhile the draft technical screening criterion for new buildings is set to 20% better than NZEB (corresponding to EPC class C in Sweden). In other word, the requirement on existing buildings will be higher in Sweden than on new buildings. This cannot be the intention of the European Commission. Since the taxonomy is intended to steer capital towards environmentally sustainable activities it is of utmost importance that the screening criteria are objective and uniform across the EU. Otherwise, there will be negative consequences for the capital markets and the real economy, without the intended benefits for the climate. • Activity Existing forest management – We regret that the draft technical screening criteria exclude existing sustainable forest management, in contrast to the final TEG proposal. European forests and forest-based products contributes to a positive carbon dioxide (CO2) abatement of more than 800 million tons per annum (CEPI 2020). Of that, the contribution from the Swedish forest-based sector is over 90 million ton (Swedish Forest Industry 2020). In addition, biomass from existing sustainable forest management offers products and solutions that help other industries make the transition to a carbon-neutral economy. Therefore, we urge the Commission to reconsider the following points: Regarding forest activities: o The reference to “improved forest management” should be replaced with “existing forest management”. o NACE codes 02.10-02.40 should be included. o The criteria outlined by the Technical Expert Group (TEG) in its final report should be reinserted after the following adjustments:  It should be clarified that national or sub-national/regional level is adequate for demonstrating forest carbon sink development.  It should be defined as voluntary to use a forest management plan (or equivalent instruments) for demonstration of permanence and steady progress. o The different natural conditions and lifecycles of forests across the EU need to be considered in climate benefit analysis. o Any references to close-to-nature management should be removed, as this concept lacks a scientifically based and broadly agreed definition. o Any reference to “additionality” should be removed, as this excludes existing sustainable forest management from being sustainable. Regarding energy: o Forest-based bioenergy should be classified as other renewable energy sources and not as a transitional activity.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

3 Jun 2015 · Priorités économiques de la Commission