German Insurance Association (GDV)

Digitalisation is essential to modern insurance services, enabling efficient claims handling, improving customer experience, and strengthening risk management. The German insurance industry remains strongly committed to supporting the digital transition and welcome the European Commissions approach to review and simplify existing digital regulations.

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.

German insurers welcome the clarifications and amendments proposed by the European Commission. We support the clarification in ESRS 1 AR 6 for para. 19-20 and para. 21 that fair presentation is assessed at the level of the sustainability statement as a whole, and that applying the ESRS leads to fair presentation. We also support the new rules on omission of information, the clarification in ESRS E1-8 AR 19 for para.

Position Paper of the German Insurance Association ID Number 6437280268-55 on the Proposal of the European Commission for a Regulation laying down harmonised rules on artificial intelligence (Artificial Intelligence Act) Introduction The insurance industry welcomes the proposed Regulation of the EU Commission on “artificial intelligence”.

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

Comment of the German Insurance Association (GDV) ID-number 6437280268-55 on the Roadmap for a Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence Gesamtverband der Deutschen Versicherungswirtschaft e. V.

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

Position Paper on European Commission’s inception impact assessment on corporate sustainable governance I. Overall position The German insurance Industry strongly supports the efforts of the EUCommission to promote the transformation to a global sustainable economy.

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

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 legislative proposal for an EU Data Act. The landmark dossier creates important foundations for data exchange and data portability. As an active participant in the data economy, the insurance industry would like to contribute to the process with the following comments: Motor insurers in particular support the Data Act, but would also prefer a dedicated, sector-specific…

The proposal for a Regulation on the European Health Data Space (EHDS) is a welcome attempt to strengthen patients’ rights in relation to their elec-tronic health data and to foster sharing and use of electronic health data for the public benefit. However, vague definitions and the resulting inadvertent-ly extensive scope of several provisions are likely to impede the uptake of the EHDS.

The German Insurance Association (GDV) welcomes the European Commission’s plans for a European Health Data Space (EHDS). Effective and secure use and re-use of health-related data has the potential to create immense benefits for the well-being of patients and society. The roadmap shows that a plethora of issues and barriers currently persist which prevent us from fully exploiting that potential.

Comment of the German Insurance Association (GDV) on the Proposal for a Regulation on disclosures relating to sustainable investments and sustainability risks and amending Directive (EU) 2016/2341 ID-Number: 6437280268-55 Gesamtverband der Deutschen Versicherungswirtschaft e. V.

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

Comment of the German Insurance Association (GDV) on the Proposal for a Regulation on the establishment of a framework to facilitate sustainable investment ID-Number: 6437280268-55 Gesamtverband der Deutschen Versicherungswirtschaft e. V.

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

Comment of the German Insurance Association (GDV) on the Proposal for a regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks ID-Number 6437280268-55 Gesamtverband der Deutschen Versicherungswirtschaft e. V.

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

The German Insurance Association (GDV) welcomes the opportunity to comment on the European Commission’s public consultation on its Sustainable Finance Initiative for the distribution of insurance-based investment products.

Please see a short summary of the comments of the German Insurance Association (GDV) below. For the complete feedback please see the document in attachment. Re-use of data held by public sector bodies GDV supports the notion that public sector data is made more easily available for re-use. For example, such data can benefit insurance in terms of risk modelling or damage prevention.

The GDV highly welcomes the EU Commission’s legislative proposal for the CSRD as an important foundation for sustainable finance. Indeed, the new CSRD – if aligned – can be a real game-changer for the sustainability agenda if it enhances market transparency, availability and quality of sustainability information.

In the current inflationary environment, rising costs for spare parts and repair are a growing concern for motor insurers and their customers. Particularly with the rapid uptake of electric vehicles, repair costs are rising disproportionately due to the lack of supply in the market and additional safety measures compared to conventional vehicles.

The German insurance industry welcomes The European Commissions commitment to addressing Europes housing crisis and its aim to achieve regulatory simplification through the Housing Simplification Package. As key stakeholders and investors in Europes long-term resilience, the industry stands as a reliable partner to support investment, facilitate construction and safeguard insurability in the housing sector.

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 welcomes the European Commissions initiative to reduce the burden of reporting and fully supports the call for evidence on the rationalisation of reporting requirements. Please find our detailed proposals in the attached position paper.

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.

We appreciate the opportunity to comment on the call for evidence. While we consider targeted modifications of existing legislation to be appropriate in some points, we are convinced that the current regulation on insurance-based investment products has, for the most part, worked well in practice.

GDV appreciates the opportunity to comment on the proposals for a new Product Liability Directive and a AI Liability Directive. The following remarks address key aspects of the proposals from the perspective of the German insurance industry. 1.

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

GDV welcomes the Commission’s examination of EU legislation on liability and product safety in the context of innovative digital and connected technologies. The PLD and national legislation are suitable and appropriate to address the risks posed by new digital technologies.

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.

01 POSITION PAPER Ref. Ares(2024)1342532 - 21/02/2024 POSITION PAPER Position Paper of the German Insurance Association (GDV) Lobby Register No. R000774 on the Commission’s Proposal for a Directive revising Directive (EU) 2015/2302 on package travel and linked travel arrangements (COM (2023) 905 final) Contents German insurers are grateful for the opportunity to comment on the Commission’s proposal for a Directive…

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

The German insurance industry generally supports the European considerations to promote a data-driven financial system. With the presented legislative proposal on a framework for access to financial data ("FiDA"), retail and corporate customers are to be given more creative scope in the use of their financial data.

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 German Insurance Association (GDV) welcomes the planned introduction of regulatory standards for ESG rating agencies and their rating activities. The proposals appear suitable to improve the quality of information on ESG ratings and to address shortcomings in the ESG rating market.

The German insurance industry welcomes the developments at the European level, the introduction of a European identity scheme (EUid) in combination with the proposed amendments of the Regulation (EU) No 910/2014 (eIDAS) by the European Commission and supports the approach to establish an EU-wide ecosystem on digital identities in form of a European identity scheme (EUid).

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 EC’s efforts to provide practical solutions for the transfer of personal data to third countries. While the draft implementation act and the updated SCCs are a great step forward, certain adjustments appear necessary and sensible.

The German insurance industry supports the strategic objective of the Cloud and AI Development Act (CADA): strengthening Europes cloud and AI ecosystem, ex panding EU-based computing capacity, improving resilience, reducing critical de pendencies and strengthening Europes digital sovereignty. A more competitive European cloud market is in the interest of insurers, policyholders and the wider economy.

The German Insurance Association GDV greatly welcomes that ESAP will be established by no later than 31 December 2024 and will provide centralized access to publicly available financial and sustainability information of relevance to investors on capital markets and necessary to comply with sustainability reporting obligations.

The German Insurance Association (GDV) welcomes the European Commission’s initiative to establish a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies.

GDV welcomes the opportunity to provide feedback on the Commission's proposal for a regulation amending the Central Securities Depositories Regulation (CSDR). Insurers as Europe's largest institutional investors in-vest extensively in securities and therefore have a great interest in a safe and efficient financial market infrastructure, where the CSDR has played a significant role in developing this infrastructure.

The German insurance industry supports the objections of strengthening policyholder and consumer protection and financial stability. We also take a positive view of the intended harmonization of resolution tools and the improvement of coordination and cooperation between the competent authorities in the various Member States.

The German insurance industry supports the Solvency II review and welcomes many aspects of the European Commission’s proposals. We are convinced that the risk-based Solvency II regulation already ensures a very high level of policyholder protection and contributes significantly to financial stability. Recently, it proved its worth in the challenges of the Covid-19 pandemic.

Summary The German insurance industry supports the modern, risk-based SII regime and believes it works well overall. Its level of security is very high. Particularly in the Covid-19 crisis, SII has proven its worth. Nevertheless, the SII review should be used for some important improvements. Regulations that are overshooting from a risk perspective should be corrected in all three pillars.

The German insurers welcome the proposed directive insofar as it aims to strengthen the creditors position in insolvency proceedings across the European Union and to increase their chances to influence the proceedings, in particular through creditors committees.

The German Insurance Association (GDV) welcomes the initiative “Enhancing the convergence of insolvency laws” and supports the recommendation to address the fragmentation of insolvency laws in EU-Member States. Insurance companies are amongst the largest institutional investors in Europe.

While a more detailed anti-money laundering regulation is ineluctable for a single AML/CFT rulebook, it is essential that it does not undermine the fundamental principle of risk-based compliance with anti-money laundering requirements. The risk exposure of obliged insurance undertakings is deemed to be moderately significant.

GDV welcomes the proposal for an EU Green Bond Standard (EU GBS). Insurers as Europe’s largest institutional investors invest extensively in bonds and therefore have a great interest in measures to stimulate the development of the green bond market as a key means of financing the sustainability transition.

Filed in German · English published by the European Commission

The German insurance industry supports improvements to the ELTIF regulatory framework. The insurance industry needs access to a wide range of assets that generate stable revenues and match its long-term liabilities. Long-term investments in the real economy, as envisaged by ELTIFs, are generally of interest for insurers, particularly for portfolio diversification purposes.

The GDV supports the designation of a European Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) with direct supervisory responsibility for selected obliged entities with significant cross-border activities and a high inherent risk profile.

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 German Insurance Association (GDV) is the association of insurers in Germany. Its more than 450 members represent over 95% of the insurance market in Germany with investments totaling 1,835 billion EUR (insurers, as of December 31, 2020), of which about one-third is invested in AIFs.

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.

The German insurance industry welcomes the opportunity to comment on the European Commission’s proposals. Unfortunately, the draft does not address the issue of the “eternal right of withdrawal”, which we consider to be crucial. Legal certainty should be created in this context by placing an absolute time limit on the right of withdrawal, for instance one year after the conclusion of a contract.

The German insurance industry welcomes the upcoming revision of the Directive concerning the distance marketing of consumer financial services (DMD), which is outdated in terms of content and no longer up to date.

The German insurance sector supports the goal of strengthening the resilience of ICT systems used in the financial sector against risks and dangers. However, this should neither lead to parallel regulatory sys-tems nor to considerable impediments. Insurers are already subject to extensive regulatory requirements such as Solvency II and Delegated Regulation (EU) 2015/35, which include ICT applications.

The GDV welcomes the focus of the Draft Directive on the organizational aspects of the institutional AML/CFT system while keeping the requirements of obliged entities separate in the AML/CFT regulation. This concept grants Member States the necessary flexibility. Please find attached the full GDV Position Paper for detailed comments on the AML Package.

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