Insurance Sweden

The SFDR proposal contains two major insurance-specific considerations are of particular importance to Insurance Sweden; the treatment of traditional life insurance products and multi-option products (MOPs). Swedish insurance and pension providers manage about EUR 700 billion, representing approximately 5% of the EU insurance and occupational pension market.

Insurance Sweden´s response to the European Commissions Have your Say consultation on the Retail investment strategy new package of measures to increase consumer participation in capital markets Insurance Sweden is the industry organisation for insurance and occupational pensions undertakings in Sweden.

As a member of Insurance Europe, Insurance Sweden shares most of the views the expressed in their response to the call for evidence on the Shareholder Rights Directive. Where we particularly diverge from Insurance Europes position in their response is that in our view fully virtual AGMs should not be allowed.

Insurance Sweden welcome this opportunity to comment on the proposed Insurance Recovery and Resolution Directive (IRRD). As a member of Insurance Europe, we share the views expressed in their response on the European Commission’s (EC) proposal of IRRD.

As a member of Insurance Europe, Insurance Sweden overall share the views expressed in its response to the European Commission’s (EC) proposed amendents in the current review of the Solvency II Directive. However, in the attached document we wish to highlight and elaborate further on the proposal to widen the corridor for the symmetric adjustment to the equity risk charge by amending Article 106 (3).