Sustainable Finance – Disclosure Rules


Position of the Association of German Public Insurers on the Joint Consultation Paper concerning ESG Disclosures according to the Disclosure Regulation

The Association of German Public Insurers welcomes the ESAs’ consultation on the proposed draft regulatory technical standards with regard to the content, methodologies and presentation of disclosures pursuant to Article 2a, Article 4(6) and (7), Article 8(3), Article 9(5), Article 10(2) and Article 11(4) of Regulation (EU) 2019/2088. As Germany’s second largest primary insurance provider with a strong regional presence, the group is committed to constructive dialogue in the interests of all market participants and of a stable European and global insurance sector.

General Comments
Sustainability is of outmost importance for all public insurers. They have signed up to the “Principles for Responsible Investment” and take environmental, social and ethical principles into account when making investment decisions. Market-driven approaches play an important role when it comes to supporting the transition to a more sustainable economy. As major investors, public insurers create an enabling framework for sustainable investments. Nevertheless, decisions to carry out sustainable projects are taken by the real economy. In this light, expectations on the contribution of financial market participants should be realistic. To increase sustainable investments of the real economy, a significant CO2-price with a clear development path would be the efficient instrument. All attempts to foster sustainable finance by increasing transparency should go hand in hand with measures to strengthen sustainable projects of the real economy.

The Disclosure Regulation can be an important puzzle piece in the comprehensive package of the European Green Deal. It will be most successful if it is

  • simple to work with it for financial market participants and investors,
  • well aligned with corresponding legal pieces (in particular the Taxonomy Regulation and the Non-Financial Reporting Directive),
  • based on existing best practices (such as disclosure according to the Principles for Responsible Investment),
  • flexible and it considers different providers of financial products,
  • proportionate and easy to comply with for companies of all sizes, and
  • based on real economy data provided in a public database.

With respect to these requirements, the association of German Public Insurers has several suggestions to improve the draft regulatory technical standards. All being members of the German Insurance Association (GDV), public insurers contributed to the comprehensive feedback of the GDV. For general points and questions not answered, public insurers also refer to the input of the GDV.

Contact Persons

Dr Wolfgang Eichert
Department of Political Affairs
Head of EU Representative Office Brussels

T+32 47 6830971

Dr Christian Schwirten
Department of Political Affairs
and EU Representative Office Brussels
Head of Department

T+49 30 22 60 549-22


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