Sustainable Finance – Taxonomy


Position on the European Commission’s Inception Impact Assessment: “Sustainable finance – obligation for certain companies to publish non-financial Information”

The Association of German Public Insurers welcomes the consultation on the delegated act required under Article 8 of the Taxonomy 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. Moreover, to increase sustainable investments of the real economy, a significant CO2-price with a clear development path would be an 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.

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


Detailed statement (PDF)

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