Regulation for the transparency and integrity of ESG rating activities


The Association of Public Insurers welcomes the European Commission's initiative to create a legal framework for environmental, social and governance (ESG) ratings. As the second largest German primary insurance provider with a strong regional presence, the group explicitly supports the goal of a more sustainable economy. Public insurers share the European Commission's analysis that ESG ratings and data are an enabler for the European Green Deal and Sustainable Finance and that they are increasingly used in risk management.

The public insurers are signatories to the “Principles for Responsible Investment” (PRI) and consider ESG criteria in all their investment decisions. From this point of view, public insurers support the approach to improve the functioning of the ESG ratings market. The Sustainable Finance Disclosure Regulation (SFDR) requires insurers to extensively document the sustainability aspects of their investments. The Taxonomy Regulation, in particular Art. 8, requires the disclosure of further sustainability indicators. Public insurers also expect the Corporate Sustainability Reporting Directive (CSRD), in combination with the EU Single Access Point (ESAP ) for corporate information, to ensure that this data is made available in an immediately usable form and free of charge in a public database.

To improve the proposed legislation on environmental, social and governance ratings and sustainability risks in credit ratings, the association makes proposals in three areas:

  • Appropriate scope of application
  • Stronger proportionality in practice
  • A balance between level I and level II

You can download the detailed statement here.

Contact Persons

Dr Wolfgang Eichert
Head of EU Representative Office
Department Political Affairs

T+32 476 83 09 71

Dr Christian Schwirten
Head of Department Political Affairs

T+49 30 22 605 49-22


Detailed statement (PDF)

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