The Association of Public Insurers appreciates the opportunity to comment on the proposed changes to the Taxonomy Delegated Regulations (2021/2178, 2021/2139 and 2023/2486) as part of the Omnibus Simplification Package. 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 the Commission’s efforts to ease regulatory burdens while upholding ambitious sustainability goals. Regarding the proposed changes to the Taxonomy Delegated Regulations, public insurers suggest the following amendments.
Remove the consolidated KPI between investment and underwriting KPIs
This KPI combines two fundamentally different KPIs (akin to adding apples and oranges), offering limited informational value to the reader. Public insurers recommend eliminating it entirely from the Taxonomy as well as from the Q&As to further streamline sustainability reporting. As this proposal is not currently included in the Omnibus Package, public insurers recommend its addition as a simplification measure.
Further simplify the templates by reducing granular details
Public insurers strongly welcome the proposals to simplify the templates. However, additional streamlining could be achieved by deleting the breakdown of covered assets. The value added is minimal; therefore, public insurers propose deleting lines 18 to 25 of the template for investments.
Facilitate reporting by introducing the 10 percent de minimis threshold
Public insurers fully support the introduction of a 10 percent de minimis threshold, which will substantially reduce regulatory burdens without materially impacting KPIs. This measure significantly simplifies reporting on investments in particular.
The Association of Public Insurers looks forward to further discussions on simplification measures and remains available for any questions.
