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Verband der Versicherungsunternehmen Österreichs / Austrian Insurance Association

VVO

Der VVO vertritt die Interessen aller in Österreich tätigen privaten Versicherungsunternehmen und unterstützt seine Mitglieder bei rechtlichen, steuerlichen, wirtschaftlichen und internationalen Angelegenheiten.

Lobbying Activity

Meeting with Angelika Winzig (Member of the European Parliament)

20 Nov 2025 · Meeting with representative of VVO

Response to Recommendation on savings and investment accounts

8 Jul 2025

The Austrian Insurance Association (VVO) would like to provide the following feedback / recommendation on savings-, and investment accounts: Any new initiative must explicitly include insurers as providers, to reach a wider audience, ensure a wider uptake in order to mobilize capital, address diverse consumer profiles and create a leverage effect through competition and innovation. Initiatives taken across different levels should be aligned, coherent, mutually reinforcing and complementary all contributing toward the EU´s goals & recent priorities. Importantly, insurers can play a key role to achieve the SIU objectives as major institutional investors in the EU and important providers of stable, long-term funding, with 9.5trn assets under management, 70% of which in Europe (EIOPA). Insurers channel peoples savings into investments through life insurance products as well as personal and occupational pension products. Furthermore, life insurance products combine investment elements and protection against biometric risks such as death, disability and longevity. Thus, life insurance does not only contribute to boost capital markets but also to tackle demographic challenges at the same time. The sector disposes of a wide array of distribution channels and a large network of distributors that are fundamentally close to EU consumers. Insurance distributors have extensive experience and knowledge of local markets and consumers needs and thus playing a specific role regarding the access for consumers to supplementary pensions and capital markets. Insurers already offer a variety of products to meet diverse consumers needs and risk profiles, and this market diversity needs to be respected. In this light, the insurance industry opposes legislative measures creating one-size-fits-all products, which stand in contrast to the given differences between member states in terms of products, distribution channels, consumers preferences, tax and pension systems. Especially the latter require national discretion for practical reasons but need to be shaped also in accordance with the EUs subsidiarity principle. The lessons of PEPP, which has failed to gain traction in the EU, show that any new initiatives must take a market-driven approach and focus on enabling increased retail investment rather than prescribing too strict requirements. The EC´s approach has to be inclusive, flexible and simple! The targets must be to attract new retail investments by mobilizing the savings currently sitting on bank accounts - not by only shifting existing investments from one to another product, as this would severely limit the benefits and the impact of the initiative. Tax incentives should be defined at national level, as this can make a real difference to mobilize retail investors. Public funds should only be used when they serve clear societal objectives and general public value, such as closure of pension gaps. Insurance products are particularly suited for long investment horizon, and different asset classes, which contribute to increase returns over time. Initiatives must also recognize the prudent person principle and the importance for investing based on the customers best interests. Flexibility in the scope of eligible assets is crucial to ensure diversification, match different consumers risk profiles and respect manufacturers freedom to design products. Boosting financial & insurance literacy remains key to empower consumers, especially regarding the need to prepare & invest for retirement and to understand the different investment opportunities available in the market. With a long-term, risk-managed and consumer-focused approach, the insurance sector brings the expertise, products and distribution network needed to make the SIU a success and to support a more resilient and competitive EU!
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Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

3 Jun 2025

The VVO welcomes 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 appreciate 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, the VVO welcomes 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 RIS, FIDA regulation 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 NSAs 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, we believe 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 are particularly relevant and important for insurance, because the need for and design of many insurance products vary nationally. This is due to 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 as outlined in the EC Simplification Communication.
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Response to Savings and Investments Union

7 Mar 2025

The VVO supports the EC´s ambition to mobilize capital to generate more investment in the EU and to strengthen the EU´s competitiveness. The much-anticipated SIU, if designed correctly, can be an enabler to growth & competitiveness by providing the necessary momentum to mobilize savings &investments to the benefit of citizens &businesses; 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 & institutional 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 & 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 major contribution to the SIU goals. The following actions can help achieve this: Ensure that the RIS contributes to the SIU objectives to allow easy access to investment products for retail investors (simpler & more targeted customer information, more efficient and customer-friendly design of advisory processes, avoidance of excessive bureaucracy in product design etc.) Improve financial education to increase recognition of the need for savings & insurance Introduce tax incentives which are key for motivating people to save for retirement Maintaining the existing diversity of products and distribution channels is of paramount importance to ensure that consumers have the widest possible choice of products & services that best meet their needs in a competitive market. A new single EU savings and investment product would run counter to a competitive market and limit the product diversity that consumers need. Take stock of why the PEPP did / does not work.; a fundamental rethinking and significant reforms are necessary Taking into account the major differences in the national pension systems in the EU, a one-size-fits-all approach for an auto-enrolment mechanism (e.g. mandatory pension scheme for all employees) has to be avoided 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. 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 recognized under Solvency II (in line with bank regime). For securitizations, 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). 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 & improving competitiveness, avoiding new regulatory burdens and reducing existing ones. It is vital that it´s applied in regard to ongoing regulatory burdens and reducing existing ones. It is vital that it is applied in regard to ongoing regulatory developments (Solvency II, RIS &FIDA). For supervision we support continued national oversight and efforts by NSAs & EIOPA to use existing tools, while respecting flexibility allowed in regulatory texts
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Response to Retail Investment Package

28 Aug 2023

The VVO (Austrian Insurance Association) generally supports the Retail Investment Strategy's goal of helping retail investors achieve higher returns and raise confidence in the capital markets in order to increase their participation in the European capital markets. The VVO welcomes the RIS proposal on financial education. It is important to promote the financial and insurance education of consumers with initiatives adapted to their different needs and age groups supporting them to better understand the information they receive. The provision of information in digital format as a standard option is appreciated. In any case, the provision of information in digital format as a standard option is welcomed. A paper copy should be possible upon request, once free of charge and will help to continue to enable the distribution of insurance products to those persons who prefer paper communication or analogue access. However, we believe that the majority of the European Commission´s (EC) intended changes to the existing legal provisions are unsuitable for achieving the RIS goals. In particular, the following issues are viewed critically: The Austrian insurance industry opposes all proposed bans on commission (including partial ones). The review period needs to be extended to at least five years in order to actually be able to draw meaningful conclusions about market developments. The planned introduction of (quantitative) benchmarks is rejected broadly, because it is in clear contradiction to existing fundamental freedoms and likely to interfere massively and without appropriate justification with the freedom of product design and product diversity. The "new best-interest approach" should be rejected, especially because it is unjustifiably overly focused on cost and might interfere with the product offer. Regarding information requirements to policyholders only general principals should be regulated at EU level on Level 1. The proposals lead to overregulation, legal uncertainty and possibly multiple implementation at high costs. The implementation period should be linked to the publication of all Level 2 measures and should be set at the earliest one year after the publication of all Level 1 & 2 measures in the OJEU. The VVO remains at the co-legislators disposal to share its expertise and elaborate on the specificities of the insurance market in order to be adequately incorporated into the legislative process & text of the RIS to benefit both, the EU´s consumers and financial markets.
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