Allianz SE

Allianz acknowledges the European Commissions continued efforts to make the standards more practical and less burdensome. We particularly welcome the new clarifications on the concept of fair presentation, which confirm its role as an overarching principle prioritising relevance and proportionality and, importantly, reaffirm that compliance with ESRS is presumed to achieve fair presentation.

Allianz highly appreciates the European Commission’s proposal for a Directive on corporate sustainability due diligence (CSDDD) with its aim to foster sustainable and responsible corporate behaviour and to anchor human rights and environmental considerations in companies’ operations and corporate governance.

We support the simplification of the SFDR to improve clarity and integration with the sustainable finance framework. At the same time, it is essential that the unique characteristics of the insurance sector are addressed in the forthcoming negotiations. Please find our detailed recommendations attached.

We generally share the high-level conclusions of the EU COM derived from the comprehensive assessment on the SFDR conducted in 2023 and agree with the EU COMs objectives for the SFDR review. While hinting at our contribution to the SFDR public consultation in December 2023, we would like to highlight the following points at this stage: (A) A categorization system for financial products can help facilitate retail…

Allianz welcomes the proposal and its objective of advancing data sharing, strengthening data availability, and thus laying the foundations for the EU data economy. We particularly support the proposed empowerment of consumers that should be achieved by facilitating access to data and giving consumers more control over who can access and use their data.

We appreciate the opportunity to comment on the EU COM’s consultation on its proposal for the Corporate Sustainability Reporting Directive (CSRD). The attached paper summarizes Allianz Group’s position, which we hope will be considered in the finalization of the CSRD.

Allianz supports the objective of creating a more integrated, resilient and competitive European financial system as outlined in the Commissions Communication on the competitiveness of the EU banking sector. Competitiveness should be pursued in a manner consistent with prudential soundness, fair competition and the principle of same activity, same risk, same regulation.

A solid framework protecting retail investors is in place in the EU The Insurance Distribution Directive (IDD), Packaged Retail and Insurance-based Investment Products (PRIIPs) and Markets in Financial Instruments Directive (MiFID II), in place for <4 years, introduced strong and effective conduct rules in the retail investment markets across the EU.

Allianz highly welcomes the establishment of a European Single Access Point (ESAP) as it constitutes an important step to improve the availability and accessibility of data, facilitate their processing and analysis, and reduce fragmentation. The attached paper summarizes Allianz Group’s key positions on the EU COM legislative proposal.

Allianz supports the objective of boosting supplementary pensions to help secure adequate retirement income, by improving access to better and more effective supplementary pensions. As such, Allianz welcomes the EU Commissions ambition to make the Pan-European Pension Product (PEPP) more attractive to providers and better adaptable to customer preferences.