Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Industry association · Germany
Declared costs: €100K+ a year · in the register since 2015
Industry association · Germany
Declared costs: €2.8M+ a year · in the register since 2008
Retail investor protection rules · Transparency and integrity of Environmental, Social and Governance (ESG) rating activities · European single access point (ESAP): access to information in relation to financial services, capital markets and sustainability
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
German Insurance Association (GDV) · filed 25 May 2022 · source
We appreciate the opportunity to comment on the call for evidence. While we consider targeted modifications of existing legislation to be appropriate in some points, we are convinced that the current regulation on insurance-based investment products has, for the most part, worked well in practice.
Association of German Public Insurers · filed 9 Aug 2023 · source
The fundamental aim of the EU Retail Investment Strategy (RIS), namely strengthening retail investors participation in Europes capital markets, is to be supported. The German Association of Public Insurers (VöV) therefore appreciates the opportunity for consultation and is ready to lend constructive support to the implementation process.
German Insurance Association (GDV) · filed 30 Aug 2023 · source
The German Insurance Association (GDV) welcomes the planned introduction of regulatory standards for ESG rating agencies and their rating activities. The proposals appear suitable to improve the quality of information on ESG ratings and to address shortcomings in the ESG rating market.
Association of German Public Insurers · filed 1 Sept 2023 · source
The Association of Public Insurers welcomes the European Commission’s initiative to establish a legal framework for environmental, social and governance (ESG) ratings. As the second largest German primary insurer with a strong regional presence, the Group strongly supports the objective of a more sustainable economy.
Filed in German · English published by the European Commission
Association of German Public Insurers · filed 15 Jan 2021 · source
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.
German Insurance Association (GDV) · filed 15 Jan 2021 · source
The German Insurance Association (GDV) welcomes the European Commission’s initiative to establish a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies.
Association of German Public Insurers · filed 1 Mar 2022 · source
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.
German Insurance Association (GDV) · filed 22 Mar 2022 · source
The German Insurance Association GDV greatly welcomes that ESAP will be established by no later than 31 December 2024 and will provide centralized access to publicly available financial and sustainability information of relevance to investors on capital markets and necessary to comply with sustainability reporting obligations.
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