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The Call for Evidence does not provide sufficient detail on the magnitude of the problems identified or the concrete proposals under consideration. Respondents are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear, making it difficult to provide meaningful feedback.

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.

Insurance Europe supports the goal of the Retail Investment Strategy (RIS) to increase retail participation in financial markets, while protecting investors from unfair practices. Within a well-designed legislative framework, insurance-based investment products (IBIPs) are key to enabling consumers to invest with confidence in capital markets, access insurance protection and prepare for old age.

Insurance Europe welcomes the EC proposal to improve the availability, integrity and transparency of environmental, social and governance (ESG) rating activities. The planned introduction of regulatory standards for rating activities should improve the quality of information on ESG ratings and address existing shortcomings in the ESG rating market.

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

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.

Please find below a summary of Insurance Europe's comments on the EC inception impact assessment on a single EU access point for company information. Our detailed comments can be found in the attached position paper.

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 European insurance industry welcomes the European Commission’s proposal establishing a European Single Access Point (ESAP). It will allow insurers, Europe’s largest institutional investors, to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format, steer their investment portfolios more effectively towards sustainability objectives and comply with their disclosure…