Gesamtverband der Deutschen Versicherungswirtschaft e.V. (GDV)

The German insurance industry supports the introduction of a harmonised corporate legal framework EU Inc., as part of an optional 28th regime. We welcome the creation of EU Inc. 28th regime company that is easy to set up and available to both young, innovative business-es and established companies.

The German insurance industry welcomes the possibility to give feedback for the EU Commissions (EC) Call for Evidence on the EU-Taxonomy. German (re)insurers support the ECs original idea of the Taxonomys framework. Despite the limited results of the Underwriting KPI, the Taxonomy made sustainability an important topic for the industry. This is evident in annual reports, process adaptations and product developments.

The German insurance industry welcomes the possibility to give feedback for the EU Commissions (EC) Call for Evidence on Taxonomy. German (re)insurers support the ECs original idea of Taxonomys framework. Despite the limited results of the Underwriting KPI, the Taxonomy made sustainability an important topic for the industry. This is evident in annual reports, process adaptations and product developments.

To ensure the practicability of the regulation, the German insurers would like to make the following remarks: Consistency with other existing or currently under development regulations (e.g., the CSRD/ESRS) needs to be ensured.

GDV appreciates the opportunity to provide feedback on the EU Commissions proposals to amend the Technical Screening Criteria (TSC) under the Taxonomy Regulation (i.e., Delegated Regulations 2021/2139 and 2023/2486). We suggest further amendments to the TSC to improve the application for users and comparability for investors.

German Insurers strongly support simplifying the current SFDR to restore its function as a customer disclosure tool. The significant simplifications introduced by the Commissions proposal are therefore a positive step, although the introduction of a categorisation system comes along with new challenges.

The German insurers (GDV) support the simplification of the SFDR to restore its value as a customer information tool. We emphasise that any such system must align with an updated IDD framework. We explicitly support the proposals by the Platform on Sustainable Finance (PSF) and the German Sustainable Finance Advisory Council.

The German insurance industry welcomes the European Commission's initiative to strengthen the EUs climate resilience and enhance risk management in the EU. Targeted climate adaptation is essential to protect our livelihoods and maintain insurability. This requires a clear legal framework.

The German Insurance Association (GDV) welcomes the European Commissions proposal to introduce the European Business Wallet (EUBW) as a central instrument for secure digital identification, authentication, signature and the exchange of tamper-proof business credentials.

German (re)insurers strongly support the objectives of the Savings and Investments Union and welcome the Commissions initiative to further integrate European capital markets and assess ways to improve supervision in the EU.

The German insurance industry welcomes the Commission’s proposal for a regulation promoting fairness and transparency for business users of online intermediation services and online search engines. Insurance companies are affected to varying degrees by the platform industry.

The Shareholder Rights Directive (SRD II), EU 2017/828, was introduced with the objective of promoting long-term shareholder engagement to ensure that decisions are taken in the interests of a companys long-term stability, whilst taking environmental and social considerations into account.

The German insurance industry welcomes the European Commissions ambitions and various measures to foster a European Savings and Investments Union (SIU). We in particular support the consultation's objective of promoting cross-border investments in the EU, reducing market fragmentation and increasing the financing provided by relevant fund segments at EU level.

The European Commissions proposal on the review of the Pan European Personal Pension Product (PEPP) is an important step in the right direction. With the right changes a modernised PEPP can help citizens build sustainable retirement income. To this end, PEPP must become a label that is recognised by European citizens.

The obligation to disclose in detail financial contributions in the form of financial services from third countries that exceed EUR 1 million places an extremely disproportionate burden on the companies concerned.

We fully support the objective of promoting broader access to occupational pension schemes. With their extensive experience, IORPs are well positioned to contribute to the expansion of occupational pension provision. According to EIOPA, in the fourth quarter of 2024, European IORPs had 74.1 million members and held 2.69 trillion in investments (around 9 % from Germany).

Filed in German · English published by the European Commission