Non-financial data is particularly relevant when ambitious and fast-paced policy actions rely on its availability, as is the case for sustainable finance. Robust, comparable and reliable environmental, social and governance (ESG) data is also vital for identifying and assessing sustainability risks in insurers’ activities and is necessary to enable investors, such as insurers, to steer their portfolios towards sustainability objectives: eg the ambitions of the Paris Agreement and of the European Green Deal.

Therefore, the Commission’s ESAP initiative is welcome. Care should be taken to ensure that any wider scope beyond ESG data does not slow down the availability of ESG data within the ESAP.

Data requirements for the ESAP must also be fully aligned with the regulatory requirements set by the Sustainable Finance Disclosure Regulation (SFDR), Taxonomy Regulation and the Non-Financial Reporting Directive (NFRD).

The ESAP could also help to minimise related costs for participants, as they would no longer be forced to rely on third-party providers for ESG data. In addition, it can help to improve transparency about ESG data and enhance the comparability and reliability of research and ratings.