The Association of Public Insurers appreciates the opportunity to respond to EFRAG's consultation on the simplification of the European Sustainability Reporting Standards (ESRS) in the context of the Corporate Sustainability Reporting Directive (CSRD). As Germany’s second-largest primary insurance provider with a strong regional presence, the group is deeply committed to the goals of a more sustainable economy. The public insurers are signatories to the Principles for Responsible Investment (PRI) and integrate environmental, social and governance principles into their business decisions. With this commitment in mind, public insurers support EFRAG’s efforts to simplify the ESRS, enhance interpretability, and eliminate disproportionate requirements, while ensuring that sustainability reporting remains meaningful and effective.
With regard to general positions on Sustainable Finance, the CSRD, and the ongoing Omnibus process for simplification, the Association refers to its previously submitted statements.
On the specific questions raised in the consultation, the public insurers comment in detail here and additionally refer to the response of the German Insurance Association (GDV).
