France Assureurs

France Assureurs is the common name of the Fédération Française de l’Assurance (French Insurance Federation) Fédération Française de l’Assurance is registered under EU transparency number No.5149794935-37 FRANCE ASSUREURS POSITION ON THE DIGITAL OMNIBUS PACKAGE The insurance sector is facing an unprecedented level of regulatory inflation at the European level, characterised by the proliferation of Level 1, Level 2…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

France Assureurs is the common name of the Fédération Française de l’Assurance (French Insurance Federation) Fédération Française de l’Assurance is registered under EU transparency number No.5149794935-37 FRANCE ASSUREURS POSITION ON THE DIGITAL OMNIBUS AI The insurance sector is facing an unprecedented level of regulatory inflation at the European level, characterised by the proliferation of Level 1, Level 2 and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

France Assureurs welcomes the work completed by the European commission in its Exposure Drafts of the ESRS and supports the overall objective of simplification and clarification of the framework. We support the Commissions decisions not to explicitly include the ISSB proposal on the non-obscuring principle in the draft, preserving legal certainty and operational feasibility for preparers and users.

The French Insurance Federation (FFA) supports the implementation of a framework for an ethical use of AI: Human-Centric, unbiased, transparent, and explainable. French residents welcome the Commission’s proposal for a risk-based regulatory framework with differentiated rules according to the risks presented by AI uses that makes it is possible to encourage technological innovation, while Guaranteeing European…

Filed in French · English published by the European Commission

FFA welcomes EC’s initiative to encourage the ethical and responsible development of artificial intelligence (AI) in the EU. AI offers economic, societal and competitive advantages to European businesses and citizens. The appropriate ethical and legal framework, based on European values, in line with the Charter of Fundamental Rights, will allow for the deployment of improved AI.

France Assureurs welcomes the proposal for a Directive on Corporate Sustainability Due Diligence aiming to prevent human rights & environmental abuses throughout the value chain. The proposal comes as a natural next step in the development of a sound legal framework which will help in delivering the goals of the Green Deal which we fully support as an industry.

France Assureurs supports the overall architecture of the proposed revision of the SFDR regulation and its objectives of enhancing the clarity of financial product categories and strengthening the credibility of the EU sustainable finance framework.

France Assureurs fully supports the SFDR and considers it to be a fundamental tool in contributing to the transition towards a sustainable economy. Although it was designed as a transparency regime, the market uses it in practice as a labelling system.

10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological…

France Assureurs supports the objective of improving healthcare delivery by ensuring that EU citizens have greater control over their electronic health data, but also to promote better exchange and access to different types of electronic health data in a private and secure environment for the common good. Therefore, we would like to highlight the following points which are detailed in the position paper attached.

DIRECTION DES AFFAIRES FINANCIERES, PRUDENTIELLES ET COMPTABLES DIRECTION DES ASSURANCES DE DOMMAGES ET DE RESPONSABILITE FFA - FEEDBACK ON THE COMMISSION LEGISLATIVE PROPOSALS ON SUSTAINABLE FINANCE AUGUST 16, 2018 1 COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON THE ESTABLISHMENT OF A FRAMEWORK TO FACILITATE SUSTAINABLE INVESTMENT All member companies of the French…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIRECTION DES AFFAIRES FINANCIERES, PRUDENTIELLES ET COMPTABLES DIRECTION DES ASSURANCES DE DOMMAGES ET DE RESPONSABILITE FFA - FEEDBACK ON THE COMMISSION LEGISLATIVE PROPOSALS ON SUSTAINABLE FINANCE AUGUST 16, 2018 1 COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON THE ESTABLISHMENT OF A FRAMEWORK TO FACILITATE SUSTAINABLE INVESTMENT All member companies of the French…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIRECTION DES AFFAIRES FINANCIERES, PRUDENTIELLES ET COMPTABLES DIRECTION DES ASSURANCES DE DOMMAGES ET DE RESPONSABILITE FFA - FEEDBACK ON THE COMMISSION LEGISLATIVE PROPOSALS ON SUSTAINABLE FINANCE AUGUST 16, 2018 1 COMMENTS ON THE PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON THE ESTABLISHMENT OF A FRAMEWORK TO FACILITATE SUSTAINABLE INVESTMENT All member companies of the French…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The French Insurance Federation (FFA) welcomes the proposal on a Corporate Sustainability Reporting Directive (CSRD). The newly suggested framework is highly relevant. French insurers particularly approve: - The concept of double materiality and the fact the CSRD encompasses the broad spectrum of sustainability topics (ESG pillars). - The extension of the scope to cover a wider part of the investment universe.

France Assureurs welcomes the European Commission's proposal on circularity requirements for vehicle design and the management of end-of-life vehicles. French insurers pay out more than 7.5 million claims for property damage every year. With a view to preserving the environment and as part of their CSR policy, they promote the repair and use of reused parts wherever possible.

The French insurance sector welcomes the European Commission’s willingness to strengthen the level of cybersecurity across the Union as it has been identified by our industry as a major challenge. A clarification of the interaction between NIS2 and DORA is however needed to allow for a harmonised framework across Europe.

France Assureurs welcomes and supports the European Commission's initiative. The proposal for a regulation on European digital identity wallets for businesses comes against a backdrop of rapid transformation in economic and administrative interactions, marked by the increasing digitalisation of processes and exchanges.

French Insurers support the texts objective to increase citizens safe participation in capital markets by strengthening their access to financial products and appropriate advice. We welcome the new measures on better understandable information and digital by default, the push for financial education and the drive to simplify precontractual information.

2022 05 31 – France Assureurs on EC Call for Evidence on RIS France Assureurs shares the EC’s ambition to increase retail investors’ confidence and trust in the capital markets. A stronger retail investment flow in the European economy would help support the European recovery, finance the double transition (digital and sustainable) and to find responses to an ageing population.

France Assureurs welcomes the opportunity to share the feedback of the French insurance industry on the European Commissions initiative to simplify the existing EU legal framework for direct taxation and boost competitiveness in the internal market.

France Assureurs would like to stress that the voice of the insurance profession is driven by the willingness to accompany technological changes, while taking into account constraints specific to the insurance operation, which requires legal certainty, indispensable for the proper functioning of the insurance/liability pair.

France Assureurs and its members welcome the revision of the Package Travel Directive. We share with the European Commission the same observations made after Covid-19, when many consumers saw their trips cancelled due to travel restrictions implemented by the States.

After a thorough examination of the Financial Data Access (FIDA) proposal, France Assureurs considers that the text in its current form raises concerns for European consumers and is unrealistic in its envisioned implementation. The numerous clarification requests from Members States confirm that this proposal should be extensively rewritten.

Core Positions of the French and German Insurance and Asset Management Industry on the EU Commissions proposal for a regulation of ESG rating activities. We welcome the proposal by the European Commission for a regulation on the transparency and integrity of ESG rating activities.

Please finish attached a detailed position of French islands regarding the revision of EU legislation on design protection. French islands pay compensations for more than 7.5 million accidents involving material damages per year. Material damages present approximate 60 % of compensation paid out by insulators. Spare shares account for half of the total cost of repairs (i.e. about 30 % of total compensation amount).

Filed in French · English published by the European Commission

COMMENTS OF THE FRENCH INSURANCE FEDERATION (FFA) The French Insurance Federation (FFA) welcomes the Commission’s review of the Design directive and Community Design Directive. The objective set in the impact assessment to fully liberalise the aftermarket of spare parts, particularly in the automobile sector, constitutes the right answer to the developments observed by French insurers.

Please find attached the comments from France Assureurs (brand name of Fédération Française de l’Assurance). France Assureurs represents the views of French insurance and reinsurance companies, totalling more than 99% of the premium income of the French insurance market.

FFA welcomes the objective of harmonization pursued by the EC, however, it is important to ensure that the shift toward a more integrated EU AML/CFT framework should consider that in France, the insurance sector is already subject to an extensive AML/CFT framework which already reaches purposes of the new proposals. Please find attached the full FFA Position Paper for detailed comments on the AML Package.

If France Assureurs considered that the current civil liability framework was fit for purpose in addressing the changes of new technologies and in particular to AI, it is essential to ensure a harmonisation of the rules at a European level.

FFA is of the opinion that AMLA could promote better coordination of national authorities and guarantee a harmonized application of AML/CFT rules within the Union. Nevertheless, crucial issues are determined at Level 2 (e.g., entities subject to direct supervision). Regarding the direct supervisory powers given to the AMLA, FFA call for more details to be provided at Level 1.

FFA welcomes the objective of strengthening the fight against money laundering within the EU, but it is important to ensure a level playing field for undertaking within the EU AML/CFT framework and to minimise costs related to central registers data.

The French Insurance Federation is grateful for the opportunity to comment on the enclosed roadmap for a review of VAT rules applicable to financial and insurance services. The industry fully supports the initiative for a global review of current applicable VAT rules.