Insurance Europe

Digital Omnibus: supporting innovation and consumer protection in the insurance sector Insurance Europe expresses its support for the overarching aim of the European Commission’s Digital Omnibus initiative. European insurers are challenged by a growing patchwork of complex and sometimes inconsistent digital regulations.

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

Insurance Europe views on the Digital Omnibus on AI Insurance Europe expresses its support for the overarching aim of the European Commission’s Digital Omnibus initiative – to lessen the administrative and compliance burdens faced by European businesses arising from the implementation of multiple regulations within the EU’s digital framework and to simplify and streamline existing rules to boost competitiveness.

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

Insurance Europe welcomes the general objective of the European Commissions Digital Package on Simplification to reduce the administrative and compliance costs associated with the application of several regulations of the EUs digital acquis, as well as the streamlining of rules through the Digital Omnibus.

Insurance Europe comments on the EC EU Inc proposal Our reference: PAC-SIU-26-016 Referring to: EC consultation on EU Inc proposal Pages: 2 Date: 25-06-2026 Transparency Register ID no.: 33213703459-54 Introduction Insurance Europe welcomes the European Commission (EC)’s recent proposal for a regulation on the 28th regime corporate legal framework – EU Inc - as an important step towards simplifying and accelerating…

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

Insurance Europe's detailed comments can be found in the document attached. Insurance Europe welcomes the European Commissions initiative to review and update the Technical Screening Criteria (TSC) under the EU Taxonomy Climate and Environmental Delegated Acts and supports the overarching objective of directing capital towards sustainable activities in line with the EUs climate and environmental ambitions.

Insurance Europe supports the European Commissions ambition to use the EU Taxonomy to channel investments toward transition-critical activities and to underpin the European Green Deal. However, the current framework has not demonstrated its value for the insurance sector and instead creates disproportionate complexity without delivering meaningful analytical benefits.

Insurance Europe and the European Insurance CFO Forum welcome the clarifications introduced on the fair presentation concept, the confirmation that reliefs (section 7.3) will be maintained on a permanent basis, the guidance on the use of reasonable and informed judgement and the specifications on the top-down approach.

As the impact of climate change on the daily lives of citizens and the broader eco-system is becoming increasingly clear, the European insurance industry is ready to continue contributing to the European Union’s political commitment to be climate neutral by 2050. The insurance industry can play a pivotal role in financing the transition to carbon-neutrality, resource-efficiency, and greater sustainability.

(Re)insurers are especially aware of and sensitive to the risks posed by a changing climate, both as an underwriter of risk and compensator of losses; and, as Europe’s largest institutional investor helping to finance the transition towards more sustainable economies.

Insurance Europe welcomes the overall objective of the Commission to create a proportionate and principles-based horizontal framework of requirements that AI systems must comply with in the EU, without unduly constraining or hindering technological development and innovation.

Insurance Europe welcomes the initiative to encourage ethical and responsible development of AI in the EU and supports the creation of an ecosystem of trust to stimulate its uptake. A European approach is necessary to limit fragmentation of the digital single market, ensure fair competition and protect European citizens & businesses.

As Europe’s largest institutional investor, the insurance sector is committed to the EU’s sustainability objectives. European insurers also strongly agree that economic activities must avoid causing or contributing to adverse impacts on human rights and the environment, and welcome corporate decisions that duly take account of a broad spectrum of considerations relevant to both the companies’ impact on people and…

Insurance Europe response to the European Commission’s public consultation on the proposal for a Directive on Green Claims Insurance Europe supports the European Commission’s objective of addressing greenwashing and misleading claims about the environmental merits of products and services.

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

Insurance Europe is the European insurance and reinsurance federation. Through its 39 member bodies the national insurance associations it represents insurance and reinsurance undertakings active in Europe and advocates for policies and conditions that support the sector in delivering value to individuals, businesses, and the broader economy.

Insurance Europe welcomes the opportunity to contribute to the European Commission's consultation on its Digital Fairness Act proposal. The position paper attached is intended to supplement the response provided via the online survey to add greater clarity and context to Insurance Europes answers.

Insurance Europe's detailed comments can be found in the document attached. Insurance Europe welcomes the European Commissions initiative to review and update the Technical Screening Criteria (TSC) under the EU Taxonomy Climate and Environmental Delegated Acts and supports the overarching objective of directing capital towards sustainable activities in line with the EUs climate and environmental ambitions.

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.

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 welcomes the proposal as it sets out common rules on the use of data generated by connected devices, including how to access and share it. We also welcome an enhanced data portability right, which, among others, looks to improve technical standards for access and portability of data generated by individuals.

Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good. For insurers, a greater availability of data could lead to improved risk monitoring and assessment, better customer experiences and increased fraud detection.

Insurance Europe welcomes the European Commission’s (EC) efforts to create an EU policy framework that unlocks the value of the data economy and creates a beneficial European Health Data Space (EHDS). The initiative has the potential to empower individuals and create new ways of communication between health care professionals and patients.

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on disclosures relating to sustainable investments and sustainability risks. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments on the EC proposal.

Insurance Europe welcomes the opportunity to provide comments on the European Commission proposal for a regulation on the establishment of a framework to facilitate sustainable investment. Please find enclosed the Insurance Europe position paper, which includes our general and detailed comments on the EC proposal.

General comments Insurance Europe 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 (IBIPs). Insurance Europe agrees that the existence of any customer ESG preferences would be a useful consideration to include during the advisory process.

General comments Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good.

Insurance Europe welcomes the overall objectives set out in the roadmap, namely: - to make more data held by the public sector usable for research and innovative uses (ie development of new products and services); - to allow individuals to consent to greater access to their data for the common good; and - to enhance overall data use in the economy by lowering transaction costs, addressing interoperability and…

Insurance Europe is very supportive of the CSRD initiative. As Europe’s largest institutional investor with €10 trillion of investments, it is vital that consistent, comparable and machine- readable sustainability data is available so insurers can make appropriate investment decisions and comply to the European regulatory disclosure requirements (SFRD and Taxonomy).

As Europe’s largest institutional investor (€10 200bn of assets under management), the insurance industry is in a unique position to help finance the transition to carbon-neutral, resource-efficient and more sustainable economies. The insurance industry is both an issuer and a preparer of non-financial information.

Please find attached Insurance Europe's response to the European Commission's public consultation on the proposed Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles, amending Regulations (EU) 2018/858 and 2019/1020 and repealing Directives 2000/53/EC and 2005/64/EC.

Insurance Europe welcomes the European Commissions (EC) ambition to raise the level of cybersecurity in the European Union through the introduction of common cybersecurity standards for digital products. The insurance industrys use of digital products will be governed by the forthcoming Digital Operational Resilience Act (DORA).

The European Commission (EC)s efforts to set up an integrated framework on climate resilience and risk management are crucial and timely. As climate change-related events become more frequent and severe, the ECs initiatives respond to very real and growing challenges that are already affecting peoples lives and livelihoods, the way businesses operate, and the stability of European economies and societies.

The Commissions initiative to issue guidance on the application of the CRA is welcome. However, the draft guidance does not explicitly address the interplay between the CRA and DORA. While the guidance explicitly notes (p. 4, section 9) that the Commission may consider issuing further guidance on the interaction between the CRA, DORA, and the AI Act, this remains open for now.

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…

Insurance Europes Perspectives IE welcomes the EC work on competitiveness and simplif, in particular the recently published Communication on the competitiveness of the EU banking sector. We welcome its recognition that a proportionate and coherent regulatory and supervisory framework is essential to support EU competitiveness and growth, while preserving financial stability and policyholder protection.

As a complementary initiative to the Digital Omnibus, the European Business Wallet (EUBW) can serve as a foundational instrument supporting secure digital identification, authentication, and exchange of company credentials across the EU.

Insurance Europe welcomes the possibility to comment on the European Commission draft Implementing Regulation laying down a list of specific high-value datasets and the arrangements for their publication and re-use.

Insurance Europe welcomes the objective of this initiative to ensure that a common EU-wide layer of public sector datasets is easily and freely available for re-use, which can lead to significant benefits for society, the environment and the economy. Public institutions can provide invaluable sources of data due to their comprehensiveness and the quality of the datasets.

Insurance Europe supports the goal of the Retail Investment Strategy (RIS) to increase retail participation in financial markets, while protecting investors from unfair practices. Within a well-designed legislative framework, insurance-based investment products (IBIPs) are key to enabling consumers to invest with confidence in capital markets, access insurance protection and prepare for old age.

The Call for Evidence does not provide sufficient detail on the magnitude of the problems identified or the concrete proposals under consideration. Respondents are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear, making it difficult to provide meaningful feedback.

Insurance Europe welcomes the European Commissions initiative to simplify EU direct taxation rules. Greater legal certainty and reduced administrative burdens are essential for ensuring that the EU tax framework remains efficient, competitive and proportionate. The attached annex sets out detailed technical proposals; the key recommendations are summarised below.

Insurance Europe appreciates the European Commissions intention to create a liability regime suitable for the digital age by revising the Product Liability Directive (PLD). However, the proposal, as currently drafted, would negatively impact the availability of insurance and would therefore not meet its intended purpose of enhancing consumer protection while encouraging innovation.

Insurance Europe welcomes the ECs effort and ambition to build a Savings and Investments Union (SIU). European insurers can play a key role in achieving the SIU goals: they provide protection to citizens and businesses, help people save for old age, are a major long-term investor in the EU economy with 9.5trn, invested in equity, corporate and sovereign bonds.

European insurers fully support the EUs objectives of making the protection of travellers more effective and to simplify and clarify certain aspects of the original Directive. This is especially relevant in the wake of the numerous challenges faced by the travel industry after the bankruptcy of the travel group Thomas Cook, and during the COVID-19 pandemic.

Open finance, if designed with the right framework, has the potential to positively impact both consumers and insurers. However, it is important to get the framework right, so that the potential can truly be achieved. This raises important considerations in relation to consent management, the scope of the data sharing and ensuring a level playing field among market participants.

Please find (below and attached) Insurance Europe's feedback on the European Commission's proposal for a Transfer Pricing directive. Insurance Europe shares the goals of the proposed Transfer Pricing (TP) directive.

Insurance Europe welcomes the EC proposal to improve the availability, integrity and transparency of environmental, social and governance (ESG) rating activities. The planned introduction of regulatory standards for rating activities should improve the quality of information on ESG ratings and address existing shortcomings in the ESG rating market.

General comments Insurance Europe welcomes the opportunity to share the views of the insurance industry on the European Commission’s proposals for a European digital identity. Digital identities and the associated processes of authentication and authorisation are an essential component of the digital single market and of national and European economies, especially against the backdrop of the COVID-19 pandemic.

Insurance Europe welcomes the evaluation of the 2014 eIDAS Regulation and accompanying revision of the current legal framework. Digital identities and the associated processes of authentication and authorisation are an essential component of the digital single market and of national and European economies, especially against the backdrop of the COVID-19 pandemic.

Insurance Europe welcomes the possibility to comment on this roadmap. Provisions around withholding tax procedures for cross-border portfolio investors or shareholders in the EU, which are different between member states, often pose a challenge to insurers in regard to cross-border investment, due to their complexity and the related costs.

Insurance Europe welcomes the opportunity to provide views on the evaluation and possible review of the Shareholder Rights Directive (SRD) promoting transparency, accountability, and long-term shareholder involvement remain highly relevant and deserve continued support. As the framework evolves, it is important that any adjustments further support efficient and well-functioning capital markets.

The European insurance industry welcomes the European Commission’s proposal establishing a European Single Access Point (ESAP). It will allow insurers, Europe’s largest institutional investors, to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format, steer their investment portfolios more effectively towards sustainability objectives and comply with their disclosure…

Please find below a summary of Insurance Europe's comments on the EC inception impact assessment on a single EU access point for company information. Our detailed comments can be found in the attached position paper.

Insurance Europe welcomes the opportunity to provide feedback on the EC’s proposal on establishment of an Insurance Recovery and Resolution Directive. Please find below our general comments. The detailed Insurance Europe comments can be found in attachment.

Insurance Europe welcomes the opportunity to provide feedback on the EC’s proposal for a Directive amending Solvency II. Please find below the key industry messages. The detailed Insurance Europe comments can be found in attachment.

We welcome the EC Inception Impact Assessment and agree to a significant extent with its objectives and policy options. However, there are some key omissions and some refinements that are necessary to ensure the right outcomes Solvency II (SII) is strongly supported but is excessively conservative and has some measurement flaws and excessive operational burdens that create unnecessary costs and barriers, in…

Please find attached Insurance Europe's position paper on the Commission's AML legislative package. Thomas Gelin Senior policy advisor Insurance Europe is the European insurance and reinsurance federation. Through its 37 member bodies — the national insurance associations — it represents all types and sizes of insurance and reinsurance undertakings.

Insurance Europe welcomes the possibility to comment on the roadmap for the introduction of a digital tax to address the issue of fair taxation of the digital economy. Key points - While data is important for insurers and reinsurers, and they use data from different sources, (re)insurance is not a highly digitalised business model.

The insurance industry welcomes the EC’s proposal for an EU Green Bond Standard (EUGBS) as a framework to facilitate capital flows to green and transition investments, in line with the Green Deal objectives. As Europe’s largest institutional investor, the sector supports measures to stimulate the development of the green bond market.

Insurance Europe welcomes the opportunity to respond to the European Commissions consultation on the review of the current ADR directive. Insurance Europe supports the reviews objective which is to adapt this framework to the digital market and its recent evolutions while improving cross-border ADR dispute resolution.

The European insurance industry welcomes the European Commission’s proposal to review the European Long-Term Investment Funds (ELTIF) Regulation. As the insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, improvements made to the ELTIF framework to make it more appealing to institutional investors are supported.

The European insurance industry supports the European Commission’s intention to make improvements to the European Long-Term Investment Funds Regulation (ELTIF) framework, as indicated in its Capital Markets Union (CMU) Action Plan (Action 3). The insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, for the benefit of its policyholders.

Insurance Europe welcomes the opportunity to contribute to the European Commission’s consultation on the proposal for a regulation for an anti-coercion instrument (ACI). Insurance Europe strongly supports the aim of the proposal; the EU should be empowered to react when a third country adopts or threatens to adopt measures to pressure the EU or a member state into making a particular policy choice.

Insurance Europe welcomes the European Commission (EC)s effort and ambition to build a Savings and Investments Union (SIU). Insurance companies are among Europes largest long-term institutional investors. With approximately EUR 9.5 trillion in assets under management, the sector plays a critical role in financing governments, businesses and infrastructure.

Insurance Europe welcomes the opportunity to provide feedback through the “Have your say” tool and wishes to raise some critical concerns and highlight the need for clarifications of some key elements of the EC’s work on the proposal for a Directive on ensuring a global minimum level of taxation for multinational groups in the EU, and for the implementation of the OECD Model Rules.

Insurance Europe welcomes the possibility to comment on the Roadmap/Inception Impact Assessment for the review of the VAT rules for financial and insurance services. We believe that an effort is required to harmonise VAT rules across Europe, establish a level playing field on VAT for all financial services providers, create legal certainty and ensure that European VAT law is fit and proper for the modern business…

Insurance Europe fully supports the European Commission's goal to strengthen solidarity and enhance coordinated EU cyber threat detection and awareness, as well as to support Member States' (MS) preparedness and response capabilities in relation to significant or large-scale cybersecurity incidents. Europes insurers notably welcome the recognition of insurance as having a role to play in enhancing cyber resilience.