Federation of European Risk Management Associations (FERMA)

The Federation of European Risk Management Associations (FERMA) brings together 23 risk and insurance management associations in 22 European countries, representing over 6,000 risk managers active in all European economic sectors. We provide a more detailed contribution attached.

The Federation of European Risk Management Associations brings together 23 risk management associations in 22 European countries, representing over 5600 risk managers active in a wide range of organisations. FERMA provides the means of co-ordinating risk management and optimising the impact of these associations outside their national boundaries on a European level.

The Federation of European Risk Management Associations (FERMA) shares the European Commissions aim to better equip the EU with the tools to ensure our access to a secure and sustainable supply of critical raw materials. We are therefore supportive of the European Commissions policy intervention in the form of the proposed Critical Raw Materials Act (the CRMA) on the premise it will help to fulfil that aim.

The Federation of European Risk Management Associations (FERMA) welcomes the opportunity to comment on the Commission’s Inception Impact Assessment, specifically on the relevant policy options and policy instruments in the area of Artificial Intelligence. Our input here is complemented by our attached position paper. FERMA brings together 22 risk management associations in 21 countries.

FERMA is a supporter of the European Commission’s ambitions to succeed in the transition to a climate-neutral and green economy and in delivering on the UN Sustainable Development Goals. From our perspective, it is overall positive to observe that the CSDD proposal borrows so much from a risk management approach. Please also find attached our position paper.

1. ON THE SIMPLIFICATION OF CYBER REPORTING European companies face an increasingly challenging environment, marked by the rising volume, complexity, and sophistication of cyber threats: since 2018, cyberattacks are considered as the most critical risk by Risk Managers worldwide (see: FERMAs Global Risk Manager survey, 2024).

FERMA is pleased to have the opportunity to provide the European Commission with feedback from the risk and insurance management community on its proposal for a Corporate Sustainability Reporting Directive [CSRD] (‘the proposal’). As the EU-level representative of the risk management profession FERMA has an important voice on the topic of sustainability.

FERMA is pleased to provide feedback to the European Commission on the proposed Cyber Resilience Act on behalf of the risk management community. While FERMA is, on the whole, supportive of the intention behind the CRA, namely to raise the level of cybersecurity of digital products in the EU (and beyond), we have some practical concerns, which we hope will be addressed by the time the text is finalised.

As the voice of European risk managers, FERMA possesses a key expertise when it comes to identifying, mapping and mitigating all risks that companies may face. This encompasses risks related to natural catastrophes (NATCAT) as Europe is facing substantial losses, destruction and costs from climate-related impacts and risks, including more frequent and intense heatwaves, droughts and heavy rainfall events.

Digitalisation and digital transformation are essential for competitiveness, resilience and innovation in the European economy. EU digital regulation should therefore support innovation and operational resilience rather than create unnecessary complexity or uncertainty. Legislation must be streamlined, coherent and proportionate across the EU digital and cybersecurity framework.

The Federation of European Risk Management Associations (FERMA) is pleased to have the opportunity to provide the Commission with its comments on the proposal for NISD 2.0. Broadly speaking we see it as a step forward that could benefit with some clarification and additional guidance in some places.

The Federation of European Risk Management Associations (FERMA) is a European professional association, which represents, through its 22 Member Associations in 21 countries, nearly 5,000 risk professionals. FERMA speaks on behalf of professional risk managers. Within our membership network, there are individuals who are responsible for the insurance programs of their enterprise.

FERMA, the Federation of European Risk Management Associations is happy to provide feedback on the European Commission's proposed amendments to Solvency II, specifically concerning proportionality. As the representative body for almost 5,000 risk and insurance managers at European level, we take great interest in the prudential rules governing insurance undertakings.