Insurance Europe has today published its response to the European Supervisory Authorities’ (ESAs) joint consultation concerning environmental, social and governance (ESG) disclosures.
Insurance Europe supports the efforts of the European co-legislators
in facilitating the development of a more sustainable economy and
welcomes the increased transparency in sustainable investments and
sustainability risks brought about by the new Sustainable Finance
Disclosure Regulation (SFDR).
Customer information is a key component in supporting the development
of sustainable finance, provided that disclosures are balanced and help
consumers make informed financial decisions aligned with their
objectives. In this context, the draft regulatory technical standards
(RTS) are a step in the right direction. However, some changes are
needed to make the disclosure regime implementable in practice and to
reflect market realities.
Proposed entity-level disclosures should be feasible with respect to
financial market participants’ activities and based on observable and
verifiable facts. In addition, the ESAs should adequately consider
implementation challenges and related timing implications, including
those related to the quality and availability of existing ESG data.
Moreover, the insurance industry takes the view that there needs to be a
phased-in approach that allows financial market participants to
implement comparable and meaningful disclosures.
Regarding product-level disclosures, there is a risk that the RTS are
too prescriptive and will result in overly complex consumer
information. Mandatory templates should also be avoided to allow for
flexibility in implementation at national level and across various
product types. The focus of the RTS should be on what information needs
to be disclosed, rather than on the form of these disclosures.
More broadly, it is essential to ensure that there is consistency
across related policy developments including the EU taxonomy, the
Non-Financial Reporting Directive (NFRD) review, and ongoing amendments
to the Solvency II and Insurance Distribution Directive (IDD) delegated
acts with respect to sustainability preferences.
Insurance Europe
© InsuranceEurope
Key
Hover over the blue highlighted
text to view the acronym meaning
Hover
over these icons for more information
Comments:
No Comments for this Article