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.
Company · Estonia
Industry association · Belgium
Declared costs: €6M+ a year · in the register since 2010
Sustainability-related disclosures in the financial services sector (SFDR) and key information documents for packaged retail and insurance-based investment products (PRIIPs) · Rationalisation of reporting requirements
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.
SEB Life and Pension Baltic SE · filed 28 May 2025 · source
We welcome the European Commission's initiative to review the area and design an optimal system that meets the needs and interests of the market and customers. As a financial market participants, we strongly support the European Commission's efforts to make the activities of the financial sector more transparent, to prioritise sustainability goals in the financial sector and to contribute to their achievement.
Insurance Europe · filed 30 May 2025 · source
European (re)insurers support an SFDR review focused on improving clarity, usability, and coherencewhile preserving its core role as a transparency framework, not a formal labelling regime. Maintaining this structure ensures flexibility for diverse sustainability strategies and insurance product types.
Insurance Europe · filed 1 Apr 2026 · source
Insurance Europe welcomes the opportunity to provide comments and our detailed feedback can be found attached. Insurers remain fully committed to the EUs sustainability agenda and to financing the green transition. However, experience with the current framework shows that complexity, legal uncertainty and frequent supervisory updates have limited its effectiveness.
SEB Life and Pension Baltic SE · filed 28 Nov 2023 · source
Taxonomy 2.8: Non-Life Business reports (s.18 and other) Previously, information was released regarding the materiality threshold for Non-life reports/templates. The impression was that the threshold would be adjusted so that Life companies with a not material percentage of non-life business would not have to report these. We do not consider that the change made is enough.
Insurance Europe · filed 29 Nov 2023 · source
Insurance Europe welcomes the European Commissions initiative to identify reporting requirements in EU legislation that can be removed or rationalised without undermining policy objectives. The insurance industry applauds the EC for its commitment to rationalise and simplify reporting requirements for companies and administrations and for its objective of reducing such burdens by 25%, in line with the strategy to…
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