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Verband der Privaten Krankenversicherung e.V.

PKV

Der Verband der Privaten Krankenversicherungen e.V.

Lobbying Activity

Meeting with Olivier Micol (Head of Unit Justice and Consumers)

8 Dec 2025 · GDPR targeted amendments through the Digital Omnibus

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

8 Sept 2025 · SFDR

Meeting with Olivér Várhelyi (Commissioner) and Fédération Française de l'Assurance

5 Feb 2025 · Mental health

Meeting with Oliver Schenk (Member of the European Parliament)

13 Jan 2025 · Europäische Gesundheitspolitik

Response to A European Health Data Space

28 Jul 2022

The German Association of Private Health Insurers welcomes the European Commission’s plans for a European Health Data Space (EHDS). In addition to the attached comments, we refer to the statement of Insurance Europe, which is fully supported.
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Meeting with Markus Ferber (Member of the European Parliament, Rapporteur)

6 Apr 2022 · Insurance Regulation: IRRD

Response to A European Health Data Space

3 Feb 2021

The German Association of Private Health Insurers has 42 ordinary and 10 extraordinary members. Its member companies cover almost the entire private comprehensive and supplementary health insurance market in Germany. We welcome the European Commission’s plans for a European Health Data Space (EHDS). In addition to the following comments, we refer to the feedback of the German Insurance Association (GDV), which is fully supported. The Association of Private Health Insurers welcomes the intended establishment of a European Health Data Space (EHDS). As part of the digitalisation of the health care system, we see the possibility of improving both the care structures and the medical care of patients. We would like to draw particular attention to the following aspects: 1) Access to the European Health Data Space The present proposals to improve preparedness and response to health crises in the EU also pave the way for the participation of the European Medicines Agency (EMA) and the European Centre for Disease Prevention and Control (ECDC) in the future European Health Data Space infrastructure. The Commission foresees that Member States will grant data authorisations to allow research institutes, health institutions and public authorities to access the EHDS. The fundamental danger of data monopolies should be taken into account when designing these access rights. In order to improve care for the insured and to be able to further expand prevention measures with a view to the digital infrastructure, private health insurers also need access to the European Health Data Space. In this way, the specific care structures can be maintained in the best possible way for the insured. In order to offer all contractually agreed benefits to their insured persons, private health insurers have to rely on being able to access relevant data. 2) Data security and interoperability The European Health Data Space should enable access to health data within a trustworthy governance framework based on clear rules and should promote digital health services. The health insured should have control over their health data, confidence in transparent and legally sound data processing and be able to share their data on a voluntary basis. As it is already the case with electronic patient records in some Member States, the Commission should develop a uniform data basis with quality criteria. This requires technical and semantic interoperability between the different infrastructures and IT systems.
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Response to Integration of sustainability risks and factors in relation to the business of insurance and reinsurance

3 Jul 2020

Dear European Commission, please find our comments of the Association of German private healthcare insurers (PKV) on Draft delegated regulation - Ares(2020)2955224 amending Delegated Regulation (EU) 2015/35 as regards the integration of sustainability risks in the governance of insurance and reinsurance undertakings in the enclosed attachment. If you have any queries, please do not hesitate to contact us. Best regards Sascha Raithel Head of Accounting/Risk Management Fon: 0049 221 / 9987-2016 PC-Fax: 0049 221 / 9987-2017 E-Mail: sascha.raithel@pkv.de Internet: www.pkv.de
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Response to Amendments to the implementing rules on solvency applicable to insurers

7 Dec 2018

Dear colleagues, We would like to thank you for the opportunity to comment on the planned changes to the Delegated Regulation in the short term. Please find our feedback enclosed. For further information please contact us at any time. Many thanks and kind regards German Association of Private Health Insurers
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Meeting with Günther Oettinger (Commissioner)

4 Dec 2017 · Health Policy

Meeting with Günther Oettinger (Commissioner)

9 Oct 2017 · Health Policy

Response to DA on product oversight and governance requirements for insurance undertakings and insurance distributors

17 Aug 2017

The German Association of Private Health Insurers (PKV) welcomes the draft Delegated Acts on product oversight and governance requirements for insurance undertakings and insurance Distributors. Please find attached our feedback.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

26 Apr 2016 · Speech on general EU policy in the financial field at "Gesprächsrunde des Jungen Wirtschaftrates Brüssel"