OpenLobby.EU
Explore

Verband Öffentlicher Versicherer

VöV

Verband Öffentlicher Versicherer is the umbrella organization for public insurers in Germany.

Lobbying Activity

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

6 Nov 2025 · NatCat

Meeting with Jutta Paulus (Member of the European Parliament)

5 Nov 2025 · Klimafolgenanpassung und -Resilienz

Meeting with Marion Walsmann (Member of the European Parliament)

15 Sept 2025 · Omnibus

Meeting with Marion Walsmann (Member of the European Parliament)

15 Apr 2025 · Omnibus I

Meeting with Rasmus Andresen (Member of the European Parliament) and Deutsche Bank AG and

9 Apr 2025 · SIU

German public insurers urge more cuts to taxonomy reporting

25 Mar 2025
Topic — This consultation reviews amendments to simplify EU taxonomy disclosures and reporting requirements.
Message — The association proposes removing the consolidated KPI that combines investment and underwriting metrics. They also suggest further streamlining templates by deleting the granular breakdown of covered assets. Additionally, they support a ten percent threshold to simplify reporting on investments.123
Why — These measures would substantially reduce regulatory burdens and simplify corporate reporting processes.4
Impact — Readers of sustainability reports lose access to detailed breakdowns of covered assets.5
Read full response

Meeting with Jutta Paulus (Member of the European Parliament)

19 Feb 2025 · Klimafolgenanpassung und -Resilienz

Meeting with Lena Schilling (Member of the European Parliament)

19 Feb 2025 · Klimafolgenanpassung

Meeting with Joachim Schuster (Member of the European Parliament)

13 Feb 2024 · review of the financial dossiers in ECON in the last legislative term

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

15 Dec 2023

The Association of German Public Insurers welcomes the initiative of the European Commission to lower the reporting obligations for companies by 25 per cent. With this in mind, the public insurers are in favour of the proposal to postpone the application of the sector-specific European Sustainability Reporting Standards (ESRS) in accordance with the Corporate Sustainability Reporting Directive (CSRD) by two years. This ensures the provision of high-quality sustainability data for the necessary transformation of our economy. As Germany's second-largest primary insurer with a strong regional presence, the association strongly supports the goal of a more sustainable economy. The association emphasises that insurers are already significant users and providers of sustainability information. The public insurers are signatories to the Principles for Responsible Investment (PRI) and take sustainability criteria into account when making investment decisions. The Sustainable Finance Disclosure Regulation (SFDR) obliges insurers to extensively document the sustainability aspects of their investments. The Taxonomy Regulation, in particular Article 8, requires the disclosure of further sustainability indicators. Public insurers also expect the CSRD, in combination with the European Single Access Point (ESAP), to ensure that this data is made available in an immediately usable form and free of charge in a public database. The association makes suggestions in three areas to further improve sustainability reporting: 1. The establishment of the CSRD as a central place for sustainability reporting 2. Proportionality in the practical implementation of the CSRD 3. Adequate implementation deadlines for Level II requirements For further details on our proposals, we kindly refer to the document attached.
Read full response

German public insurers call for broader ESG rating rules

1 Sept 2023
Topic — This initiative seeks to regulate the reliability and transparency of ESG ratings.
Message — They propose expanding the regulation to include all non-public ESG information. They also want explicit legal safeguards for smaller rating providers.12
Why — Better market competition would lower costs for insurers purchasing sustainability data.34
Impact — Large data firms lose their market power as natural monopolies are restricted.5
Read full response

German Public Insurers Demand Revisions to Retail Investment Strategy

9 Aug 2023
Topic — The European Commission's plan to increase retail investor confidence and capital market participation.
Message — The association requests a reduction in secondary regulations and realistic implementation deadlines for IT systems. They also reject any ban on commissions for execution-only sales and price-controlling benchmarks.12
Why — Reducing regulations and keeping commissions protects their revenue and lowers administrative spending.3
Impact — Retail investors face increased confusion from excessive information and potentially restricted product options.4
Read full response

German Public Insurers Urge Alignment in EU Sustainability Standards

7 Jul 2023
Topic — The European Commission is establishing new mandatory sustainability reporting standards for large companies.
Message — The group wants reporting rules aligned to simplify how they collect data. They also request that carbon accounting standards remain voluntary to ensure legal certainty. Finally, they suggest presenting impact data in a separate table.123
Why — Aligned reporting standards would lower administrative costs and simplify the consolidation of data.4
Impact — Transparency advocates lose granular data when companies report immaterial impacts as simple zeros.5
Read full response

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

5 Jul 2023 · Insurance Regulation: Solvency II

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

3 Jul 2023 · Corporate Sustainability Due Diligence

Meeting with René Repasi (Member of the European Parliament, Rapporteur for opinion)

19 Jun 2023 · EU-Lieferkettengesetz/ Corporate Sustainability Due Diligence Directive - Staff Level

Meeting with Rasmus Andresen (Member of the European Parliament)

1 Jun 2023 · CMDI

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

8 Nov 2022 · Insurance Regulation: Solvency II

Response to EU single access point for financial and non-financial information publicly disclosed by companies

1 Mar 2022

The Association of German Public Insurers strongly welcomes the European Commission's initiative to strengthen the availability of sustainability data. The Sustainable Finance Disclosure Regulation (SFDR) requires insurers to disclose the sustainability data of their investments. The Taxonomy Regulation, specifically Art. 8, requires disclosure of additional sustainability indicators. The public insurers expect ESAP, in combination with the Corporate Sustainability Reporting Directive (CSRD), to provide this all data in a directly usable form, as well as free of charge, in a public database. The proposed regulation is a therefore an important step into the right direction. The association therefore emphasizes the following four aspects, especially with regard to the contributions of the co-legislators European Parliament and Council: 1. Complete dovetailing of SFDR, taxonomy regulation and CSRD 2. Availability of sustainability data for all asset classes 3. No additional reporting burden for companies 4. A Roadmap to ensure a timely ESAP-launch 1. Complete dovetailing of SFDR, taxonomy regulation and CSRD Discussions on the data to be disclosed through the CSRD are still ongoing. In combination with ESAP, there should be a close interconnection so that all mandatory data for the disclosure of insurers and other financial market participants according to SFDR and the Taxonomy Regulation can be retrieved in ESAP. Otherwise, the quality and comparability of the data for SFDR and the Taxonomy Regulation would be counteracted. 2. Availability of sustainability data for all asset classes In line with the first point, the German Association of Public Insurers suggests including data from other investment objects. All asset classes, especially government bonds, which is particularly relevant for insurers, should be taken into account in ESAP. The proposal should therefore be extended such that the data from public institutions required for SFDR and the Taxonomy Regulation must be included by them in ESAP as well. The additional, voluntary inclusion of non-European sustainability data from companies and other asset classes in ESAP should also be made possible. 3. No additional reporting burden for companies The German Association of Public Insurers strongly welcomes the fact that ESAP does not create any new reporting obligations for the companies, but rather compiles existing data centrally. This principle should be strictly upheld in the negotiations of the co-legislators. The association supports the use of the Legal Entity Identifier (LEI) as the central identifier for ESAP, as was also suggested in the contribution to the impact assessment in the initial phase. 4. A roadmap to ensure a timely ESAP-launch In light of the increasing data need and disclosure requirements of insurers, the timely launch of ESAP by December 31, 2024 is essential. An implementation roadmap with milestones on the development of implementing technical standards (ITS), the set-up of the database and other aspects is therefore necessary. Furthermore, given the enormous technical complexity of creating such a database, we suggest to support ESMA with an expert group. For further details for an efficient organisational and technical implementation, we refer to the position of the German Insurance Association (GDV). The public insurers support the European Commission in the implementation of this ambitious project. It will be an important link between the different regulatory frameworks in the field of sustainable finance. The German Association of Public Insurers look forward to further exchanges on sustainable finance, the contributions of the Parliament and the Council, as well as the cooperation with them.
Read full response

Response to Revision of Non-Financial Reporting Directive

13 Jul 2021

The public insurers are signatories of the Principles for Responsible Investment (PRI) and take environmental, social and governance principles into account in their investment decisions. In this light, the public insurers strongly support improved sustainability data. The Sustainable Finance Disclosure Regulation (SFDR) requires insurers to report an extensive set of sustainability data of their investments. The Taxonomy Regulation, particularly Art. 8, calls for the disclosure of additional sustainability indicators. The public insurers expect the Corporate Sustainability Reporting Directive in combination with the European Single Access Point to ensure that all these are available, ready to use and free of charge in a public database. To improve the proposal for the Corporate Sustainability Reporting Directive, the Association of German Public Insurers has recommendations in two areas: first, the scope of the directive and proportionality and second, the focus on stakeholder needs. Scope of the directive and proportionality The scope of the Non-Financial Reporting Directive is limited to capital market oriented companies and public-interest entities with more than 500 employees. The public insurers fully support the approach to extend the scope to all companies and they would keep the threshold of 500 employees or at maximum, go to a threshold of 250 employees. The proposal foresees to include all “large companies” as defined in the Accounting Directive. While this definition might be appropriate for the real economy, it would include insurers with significantly less than 250 employees due to the typical size of the revenues and premiums of insurance undertakings. The public insurers therefore suggest keeping the threshold in terms of employees. If a threshold of 250 is chosen, they propose to include the same proportionality measures for companies with less than 500 employees as foreseen in the proposal for capital market oriented small and medium-sized enterprises (less reporting and transition periods). However, requirements for all companies should include the disclosure of sustainability data needed for the SFRD and the Taxonomy. Stronger focus on stakeholder needs The needs of stakeholders of large, international and capital market oriented companies and those of small and medium-sized, regional and public companies are different. The current proposal does not account sufficiently for these differences. In addition to the proportionality measures in the first section, the public insurers suggest aligning sustainability-reporting obligations of non-listed companies. In comparison to capital market oriented companies, they do not have capital market investors as stakeholders. Their sustainability reporting standards should reflect this and be more proportionate. Furthermore, non-listed companies should maintain the flexibility to include their sustainability disclosure in their annual management reports or publish it separately. Consequently, they should not be obliged to conduct limited assurance for their sustainability requirements. As it is already the case now, many companies will voluntarily opt for assurance if it is of benefit for their stakeholders. German Public Insurers encourage the European Commission to pursue this ambitious project. It will be instrumental in aligning the different regulatory components of Sustainable Finance.The public insurers are looking forward to continuing the exchange on Sustainable Finance.
Read full response

Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Jan 2021

The Association of German Public Insurers (www.voev.de) welcomes the initiative of the European Commission to create an EU-wide platform for company information, in particular for sustainability data. So far, the availability of high quality, reliable and comparable data is insufficient to comply with the increasing expectations and new regulatory requirements in the realm of sustainable finance. Full reporting according to the Sustainable Finance Disclosure and the Taxonomy Regulations is currently not possible due to the lack of real economy data on sustainability. For the time being, insurers have to compile the data via various third party providers, who use different methodologies and estimates. As a consequence, quality and comparability are not given. Data for all mandatory indicators of the mentioned regulations should therefore be available on the platform to ensure quality and comparability. Public Insurers suggest including data of other investee objects than companies in the database as well. Furthermore, the disclosure of sustainability data of the real economy should be extended in the course of the upcoming revision of Directive 2014/95 on the disclosure of non-financial information. The aim is to create a platform containing all sustainability data required in the Sustainable Finance Disclosure and the Taxonomy Regulations as well as in upcoming legal acts. It should be public, free of charge and contain sustainability data for all asset classes. All entities on the platform should have a unique identifier, preferably the legal entity identifier (LEI). With this identifier, insurers and other financial market participants should be able to automatically assess, download and calculate the indicators required by the mentioned legal acts. To further increase the value added of the EU-wide platform, it should include data from non-EU countries as well. The database should be open for companies that are not listed in the single market. They should have strong incentives to provide their sustainability data to be attractive for investors in the EU. German Public Insurers encourage the European Commission to pursue this ambitious project. It will provide the data basis for the transparency of sustainable investments and constitute an important missing link to align the different legal pieces of Sustainable Finance.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

For a successful implementation of the Taxonomy, German public insurers identify three key factors: 1. Public accessibility of sustainability data of the real economy: Therefore, the Association of German Public Insurers supports the Single Access Point initiative of the new Capital Markets Union action plan – the establishment of an EU-wide platform for financial and sustainability information. Sustainability data for all asset classes should be available and the database should be publicly available. The data provision and maintenance should also be defined in the course of the upcoming revision of the EU Directive 2014/95 on the disclosure of non-financial information.   2. Level playing field for all types of financial products: Only a small fraction of the typical capital allocation of insurers is compatible with the Taxonomy. In particular, government bonds as one of the most significant asset class are not considered yet. Therefore, the Association of German Public Insurers strongly welcomes the establishment of an EU Green Bond Standard. The public insurers strongly support the goal to accomplish sustainability classifications for all asset classes. 3. Applicable implementation of the technical screening criteria: The successful implementation of the Taxonomy Regulation requires a balance between the effective exclusion of green washing risks one the one hand and a simple implementation on the other hand. For the technical screening criteria of non-life insurance, public insurers have proposals to strike the right balance between both goals. Comments on non-life insurance activities: German public insurers strongly support the consideration of non-life insurance services as potential sustainable activities in the Taxonomy Regulation (Annex II, p. 263-266). However, the technical screening criteria need some changes to be applicable, especially in the context of the “do not significant harm” (DNSH) criterion. The exclusion of insurance of activities related to the extraction, storage, transport or manufacture of fossil fuels is problematic for several reasons and should therefore be removed. • The approach is inconsistent with the screening criteria of other activities in the Taxonomy Regulation. If insurance as intermediate service in the value chain of fossil fuels is not compatible with the Taxonomy, this should also be applied to all other intermediate services as well. According to this perspective, no supplier of intermediate goods or services realted to fossil fuel activities would be sustainable. In addition, subsequent value chain stages would also have to be taken into account. For instance, users of electricity from fossil fuels would also have to be excluded from the list of sustainable activities. • The draft does not consider that a majority of the EU member states already implemented measures and defined exit paths to withdraw from fossil fuels (e.g. withdrawal from the coal-based power generation in Germany). On this exit path, insurance coverage is essential for protecting citizens, corporates and sovereigns from risks. Neither insuring nor not insuring these risks would have an impact on environmental goals, as the sector is already on a legal exit path. • The overall blanked exclusion is an obstacle for the green transformation of the energy sector: Numerous providers of fossil fuels are already switching to renewable energy sources. During this transformation, they need adequate insurance coverage. Hurdles in obtaining insurance protection would therefore lead to obstacles in the green transformation process at the same time. • The criterion is not applicable as it is not verifiable by the insurer: Insurers can neither control nor rule out that for instance an insured vehicle is used for the transport of fossil fuels. Keeping this criterion as DNSH would in fact automatically exclude all non-life insurance services from the classification as sustainable activities in line with the Taxonomy.
Read full response

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

Comments on reporting of non-financial undertakings German public insurers fully support the approach to use the Non-Financial Reporting Directive (NFRD) to compile the real economy data necessary for sustainability reporting. Standardized, high quality data is particularly important for the reporting obligations of the Sustainable Finance Disclosure Regulation (SFDR). The delegated act of the Taxonomy Regulation should require investee undertakings under the scope of the NFRD to disclose all the data needed in terms of the SFDR. The data of investee objects for all mandatory indicators of the SFDR should be available in a standardized public database. In addition, the reporting needs to be done in an electronic way and directly feed into this database. This is also the best way to ensure the quality and comparability of the data. An individual, direct collection of data from the invested companies by each financial market participant is neither appropriate nor efficient. Furthermore, the timelines for the application of the delegated act and the reporting requirements of the SFDR must be aligned. Financial undertakings under the scope of the SFDR highly depend on standardized high quality data provided within the scope of the NFRD. An application of the SFDR reporting obligations before the delivery of data of investee objects puts the quality of disclosure and comparability for consumers at risk. Comments on reporting of financial undertakings Reporting requirements should be based on existing best practices (such as disclosure according to the “Principles for Responsible Investment”). They should be proportionate and easy to comply with for companies of all sizes. Furthermore, consistency of all Sustainable Finance disclosures is the key for their credibility and acceptance by investors, in particular retail investors. Different data sets would be confusing and put the success of these important endeavours at risk. Given the comprehensive disclosure obligations for insurers according to the SFDR and Solvency II, the required data of Article 8 of the Taxonomy Regulation is already available, for both life and non-life insurance. For life insurance, the SFDR already guarantees full transparency of financial undertakings and additional disclosure creates no value added. If there were needs by investors for further information, these requirements would have been considered directly in the SFDR. Therefore, introducing new obligations for financial market participants under the scope of the SFRD by means of Article 8 of the Taxonomy Regulation would contradict the SFDR. Article 8 defines the reporting requirement as “information on how and to what extent the undertaking’s activities are associated with economic activities that qualify as environmentally sustainable under Articles 3 and 9 of this Regulation”. As investing the customers’ premium payments is an essential part life insurance, the requirements of Article 8 of the Taxonomy Regulation are already fulfilled with the SFDR disclosure. For non-life insurance, the final report of the European Commission’s Technical Expert Group states on page 572 of the technical annex: “Such insurance represents an important element for climate change adaptation... ”. Non-life insurance, and in particular residential building insurance, contributes significantly to climate change adoption. The Technical Expert Group thus identifies a number of non-life insurance lines of business that are Taxonomy-eligible. In light of the recommendations of the Technical Expert Group, data on the aggregated share of eligible lines of business are sufficient to comply with Article 8 of the Taxonomy Regulation. These data, which are readily published in annual reports of insurers according to the Solvency II framework, provide a full view “on how and to what extent the undertaking’s activities are associated with economic activities that qualify as environmentally sustainable”.
Read full response

Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

6 Jul 2020

The Association of German Public Insurers (VöV, www.voev.de) welcomes the proposed clarifications on sustainability in the Delegated Regulation of the Insurance Distribution Directive. As signatories of the Principles for Responsible Investment, all German Public Insurers have incorporated sustainable investments into their business models. A coherent framework for sustainable finance will reinforce this competitive advantage of them as responsible investors. Consistency of all European (and national) pieces of law is key for the success of this endeavour. The Sustainable Finance Disclosure Regulation (EU) 2019/2088 distinguishes between two types of products: those promoting environmental and social characteristics (Article 8 products) and those pursuing sustainability objectives (Article 9 products). The same classification should be applied in context of the Insurance Distribution Directive (as well as other sectoral directives). However, the proposed changes to Delegated Regulation (EU) 2017/2359 on sustainability preferences comprise a further differentiation of Article 8 products: those pursuing sustainable investments as defined in Article 2, point (17) of the Sustainable Finance Disclosure Regulation, and those considering principal adverse impacts on sustainability factors, as referred to in Article 7(1), point (a) of that Regulation. The VöV does not see a value added for investors in creating these new two types of sustainable products. This further differentiation risks that products might be entitled to be marketed as promoting environmental or social characteristics under the Sustainable Finance Disclosure Regulation, but cannot be offered to clients with sustainability preferences. The interplay between the different pieces of Sustainable Finance legislation is already complex and overburdening it would create unnecessary obstacles for sustainable investments. The VöV believes that the framework will be most successful if it is kept as simple as possible. Therefore, the VöV advocates deleting the following enumerations in the suggested changes to Delegated Regulation (EU) 2017/2359 Article 2 (4): (i) pursues, among others, sustainable investments as defined in Article 2, point (17), of that Regulation (EU), or (ii) as of 30 December 2022, considers principal adverse impacts on sustainability factors, as referred to in Article 7(1), point (a) of that Regulation;
Read full response

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

5 Mar 2020 · Solvency II, sustainable finance, Pan-European Personal Pension Product